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Streamlined Domestic Offshore Procedures: How to Apply 2021

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

How Does OVDP Willfulness Impact Citizenship (I-485 & N-400)?

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)

Litigating Form 3520 in Tax Court to Fight IRS Assessable Penalties

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
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