I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Two courts have limited the FBAR “willfulness” […]
The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS). The case was initiated by […]
I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating […]
US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe. Today’s […]
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. […]
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 […]
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 […]
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, […]
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 […]
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 […]
