Courts throughout the country have provided holdings that further complicate the issue of how courts will address penalties for non-willful FBAR violations. Opposite opinions highlight need for clarity The Ninth Circuit recently held in United States v. Boyle that the...
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International Tax Law
Two important lessons from the “biggest ever” tax evasion case
Federal prosecutors recently charged Texas billionaire Robert Brockman with multiple tax crimes. Officials state this is, to date, the largest tax evasion crime the country has seen. Mr. Brockman, arguably one of the nation’s most prominent philanthropists, now faces...
IRS takes another step to address taxpayers with offshore accounts
United States taxpayers are allowed to have accounts overseas. Offshore accounts are not illegal. What is illegal — failing to report these assets. The Internal Revenue Service (IRS) frowns upon attempts to keep these assets hidden. The failure to properly report...
Undisclosed assets and inheritance: Will the IRS notice?
Getting an inheritance can come with certain obligations. In some cases, these obligations can include filing paperwork with the Internal Revenue Service (IRS). But what happens if you do not? The answer depends on the details of the situation. A recent case provides...
To report or not to report: Why is virtual currency so difficult?
Governments are struggling with how to manage virtual currency. The Internal Revenue Service (IRS) and Department of Treasury continue to struggle to find the right way to handle this asset and have taken different stances. Digital currency has similarities to other...
IRS reminds taxpayers to report foreign assets
Tax Day has passed, but some taxpayers may have missed an important form. In certain situations, the government requires taxpayers to file additional paperwork. One example: foreign accounts. The Internal Revenue Service (IRS) recently published an...
Got foreign accounts? IRS has new reporting requirements.
The Internal Revenue Service (IRS) recently announced new reporting requirements for United States taxpayers with foreign accounts. The change is in part due to the sunset of the offshore voluntary disclosures program (OVDP). Who can benefit from the new program? The...
Partnership tax audit rules: Is your business ready?
The rules regarding how the Internal Revenue Service (IRS) can conduct tax audits of partnerships have changed. It is important for business owners to review the rules and have a basic understanding of the impact on their business. In some cases, business owners may...
Can you avoid huge tax penalties when the OVDP is about to end?
The Internal Revenue Service (IRS) requires taxpayers to report certain foreign assets. This requirement has led to many questions, including what should you do if you have a foreign asset? Can you come into compliance without facing serious penalties? In short yes,...
IRS continues its crackdown on need to report foreign assets
The Internal Revenue Service (IRS) has taken the failure to disclose foreign assets very seriously. Taxpayers that neglect to disclose this information can face serious fines and potential criminal charges. Who needs to file and FBAR? The United States government...