Don Fort was appointed Chief of Criminal Investigation (CI) for the Internal Revenue Service (IRS) in June. He’s quickly making his presence known as the IRS’ top […]
IRS CID Chief: “Significant” International Tax Investigations Under Way
Category: FATCA
Foreign Owner / Foreign Assets: No US Nominee!
We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by banks in Switzerland and elsewhere, as well […]
The Human Side of Expatriation
I recently wrote a tax blog post, titled “Number of 2017 US Expatriations Exploding”. It was of interest to a great number of readers. Given the interest that […]
United Arab Emirates, Lebanon + 11 Others Now “Largely Compliant” With International Tax Transparency Rules
Various jurisdictions that had failed to demonstrate compliance with international tax transparency standards, including the United Arab Emirates (UAE) and Lebanon, just had their ratings upgraded by the […]
Congressional Committees Back Coinbase – IRS Rebuked!
Republicans in Congress just sent a harsh rebuke to the Internal Revenue Service (IRS) suggesting the IRS has overstepped its boundaries by issuing a very broad “John Doe” […]
To Be or Not to Be – A Participant in a DOJ Non-Prosecution Program?
Over three years ago, the US Department of Justice (“DOJ”) and Swiss authorities jointly announced a landmark non-prosecution program for any Swiss bank that was not a current target of […]
IRS Budget on the Chopping Block – Taxpayers Must Prepare for Greater IRS Aggression
President Donald Trump released his “Budget Blueprint on March 16, “America First, A Budget Blueprint to Make America Great Again”. The Budget Blueprint “reprioritizes” Federal spending so that […]
Reporting Rules Now Apply to Disregarded Foreign-Owned US LLC
The US Internal Revenue Service (IRS) recently published final regulations (the “Regulations”) under section 6038A of the Internal Revenue Code that address reporting and recordkeeping obligations of US […]
So, Sir Patrick Stewart Wants to Become a US Citizen?
Sir Patrick Stewart (yes, despite rumors to the contrary, I know you are still alive), I understand you want to become a US citizen so you can “fight” President Trump […]
IRS Has a New Audit Strategy – Focus OVDP Withdrawals and Declines
Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division now has a new audit strategy known as “campaigns.” For the past several years, the LB&I Division has […]