We had a very interesting case decided May 16 2018 when a district court in Texas granted Dominique Colliot’s motion for summary judgment (United States, v. Dominique G. […]
Can You Claim a Refund of Your “Willful” FBAR Penalty?
Category: FATCA
Consequences of Involving an American in Your Non-US business
Most people would never imagine that having an American business partner or employee (or even an American spouse) could result in having to disclose their business’ finances to […]
WEBINAR: Time is Running Out – OVDP Closing. FATCA Enforcement Starting.
Time is Running Out – OVDP Closing. FATCA Enforcement Starting. Come Learn at Our Free Webinar April 10th 8:00 PM – 9:00 PM GST Register here. Last month […]
Confused Yet? W-8BEN, W-8BEN-E, Foreign ITINs and Dates of Birth
Compliance with the Foreign Account Tax Compliance Act (“FATCA”) enacted 8 years ago, has resulted in a plethora of new US tax reporting requirements, forms and rules. Unfortunately, […]
Fairness? IRS Just Updated Coordination Between Streamlined Procedures and OVDP
Many of my readers will recall my earlier posts on the Streamlined Procedures and the Offshore Voluntary Disclosure Procedures (OVDP). In 2014, the IRS greatly revamped the Streamlined […]
IRS On a Roll with Passport Denials and Revocations – $51,000 Covered!
Yesterday the Internal Revenue Service (IRS) “strongly encouraged” taxpayers who are seriously behind on their taxes to pay what they owe or enter into a payment agreement with […]
Revocation or Denial of US Passport for Tax Debt – It Has Begun
If you have “seriously delinquent tax debt”, Internal Revenue Code Section 7345 authorizes the Internal Revenue Service (IRS) to certify that unfortunate fact to the State Department. Once the State […]
Part II: Foreign Data In Chaos at IRS
My earlier blog post introduced the notion that chaos reigns over at the offshore information vault maintained by the Internal Revenue Service (IRS). My post detailed how the […]
FATCA? Who Cares? Information CHAOS at the IRS
A September 11, 2017 Report (Report) by the Treasury Inspector General for Tax Administration (TIGTA) revealed that the Internal Revenue Service (IRS) is not up to speed in […]
IRS CID Chief: “Significant” International Tax Investigations Under Way
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 […]