...firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts....
In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or...
...a small number of taxpayers could account for most of these penalties. In other words, the IRS Taxpayer Advocate’s Report states that the IRS required benign actors (small fish with...
Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a...
...it to FinCEN (not the IRS) by June 30 of the following year on Form TD F 90-22.1. Note that this is not a tax filing, so FinCEN must receive...
...or abroad with tax questions can use the online IRS Tax Map to get answers. An International Tax Topic Index page was added recently. The IRS Tax Map assembles or...
...amnesty program and to pay $5 billion in taxes, federal prosecutor Scott McBride told U.S. District Judge Freda Wolfson. The program lets taxpayers repatriate assets by paying back taxes and...
...have hidden their accounts from the IRS. HSBC’s is one of at least 11 banks under investigation by U.S. prosecutors investigating offshore tax evasion. Since 2009, at least 84 people...
...Division. IRS officials from the Offshore Compliance Initiative office agree that more could be done to improve taxpayer education and outreach about offshore reporting requirements. They [IRS], like us [GAO],...
...anticipated relocation. Your estate planning documents should, at minimum, also include a Durable Power of Attorney and advance medical directives. Reciprocity may apply to these additional estate planning documents. Most...
...IRS’s four offshore programs have resulted in more than 39,000 disclosures by taxpayers, producing over $5.5 billion in revenue. The offshore disclosure programs attract taxpayers by offering a reduced risk...
...that could benefit from additional taxpayer education and outreach and potentially improve voluntary compliance by taxpayers with new offshore accounts,” the GAO said. The offshore amnesty programs attract taxpayers by...
