6c628c2634f6489cf08280411e3dc99f Archive

TweetShareSharePin0 Shares Streamlined Domestic Offshore Procedures Streamlined Domestic Offshore Procedures (IRS) Streamlined Domestic Offshore Procedures: Since the IRS both closed OVDP (2018) and ended DIIRSP (2020), the big question is whether Streamlined may be next up on the chopping block. The Streamlined Procedures are a great offshore disclosure program. In 2014, the IRS developed the

TweetShareSharePin0 Shares   International Tax Law, Immigration & Offshore Disclosure International Tax Law, Immigration & Offshore Disclosure International Tax Law & Immigration: Oftentimes, foreign individuals who are considered US Persons randomly stumble upon the fact that they are subject to IRS tax and offshore reporting requirements. This news can come as a big (and unwelcome)

TweetShareSharePin0 Shares Taxes for Expats Taxes for Expats Taxes for Expats: When an American or U.S. Person relocates outside of the United States and resides permanently away from the U.S., they are referred to as an “Expat.” Technically, they may not be an expatriate in the sense that they have not formally relinquished their Legal

TweetShareSharePin0 Shares   Is “I Didn’t Know” I Had to file FBAR a Defense to Penalties? “I Didn’t Know I Had to File FBAR” Penalty Defense Is “I Didn’t Know I Had to File FBAR” a Defense to Penalties: The answer is that sometimes, the “I Didn’t Know I Had to File FBAR” defense can work.

TweetShareSharePin0 Shares   Court Rules FBAR Penalties May Survive Death FBAR Penalties May Survive Death FBAR Penalties May Survive Death: In the past two years, there have been many recent court rulings on matters involving the FBAR (Foreign Bank and Financial Account Reporting) and how penalties should issued and upheld. When a Defendant’s back is

TweetShareSharePin0 Shares Risk of Form 3520 Collection Due Process Hearing Risk of Form 3520 Collection Due Process Hearing: IRS Overview Risk of CDP in Form 3520 Penalty Dispute Matters: When a Taxpayer receives an IRS CP15 notice regarding a Form 3520 penalty — usually for receiving a large gift from a foreign person — they

TweetShareSharePin0 Shares Litigating Form 3520 Penalties in Tax Court Tax Court for Form 3520 Litigation of IRS Assessable Penalties  Tax Court for Form 3520 & Litigating IRS Assessable Penalties:  In the past few years, the IRS has significantly increased assessment and enforcement of Form 3520 penalties (6039F) — along with several other international information return