Kevin Packman

Kevin Packman

Holland & Knight LLP

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IRS Unveils New Compliance Program

According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more

6/4/2014 - Compliance FBAR Income Taxes International Tax Issues IRS Offshore Funds Tax Evasion

States Fight Back and Employ Creative Techniques to Collect Tax & Tolls

States are fighting back. While they may not have the same resources available to combat tax avoidance, as the Internal Revenue Service or Department of Justice, they are resorting to creative measures. ...more

3/28/2014

Nonresident Alien Who Was Previously a U.S. Resident Indicted for Tax Crimes

On March 20, 2014, a federal grand jury in Kansas City, Missouri indicted Victor Lipukhin for tax crimes that occurred from 2002-2007. What makes this indictment stand out when compared against many others is that the...more

3/26/2014 - Non-Resident Aliens Tax Evasion Tax Liability

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

3/17/2014 - Banks FATCA Foreign Banks OECD Offshore Funds OVDP Tax Evasion

The Broad Reach of the Internal Revenue Code’s Taxing Power

Two interesting stories coming out of California were reported in the media last week, both of which dealt with the issue of what constitutes taxable income. Generally speaking Internal Revenue Code Section 61 defines what...more

3/4/2014 - Income Taxes IRC Property Tax

Israel's 10-Year Tax Holiday for Immigrants Is No Tax Haven for Ex-Pats

While Israel welcomes immigrants, and even provides them with tax incentives, it is serious about ending any perceived notion that it is somehow complicit with taxes evaded by its foreign residents in their home country. As...more

2/28/2014 - Expatriates Immigrants International Tax Issues Middle East Tax Haven

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

2/26/2014 - Income Taxes Offshore Banks Offshore Funds OVDP Tax Evasion

Even Though IRS Executives Do Not Know It, Employee Travel Reimbursements Can be Taxable

On Tuesday, February 18, 2014, the Treasury Inspector General for Tax Administration (TIGTA) issued a report reviewing the long-term travel of certain IRS executives and found that nine of the thirty one executives whose...more

2/25/2014 - Income Taxes IRS Reimbursements Travel

Avoid Identity Theft Tax Troubles

Anyone can become a victim of identity theft, and it can happen anywhere. Michael Stores, Neiman Marcus and Target are simply the latest merchants to report that customer information was stolen. While being a victim of...more

2/7/2014 - Identity Theft Personally Identifiable Information

FBAR and Form 8938 Assistance Provided by Treasury

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

1/30/2014 - Banks FBAR Foreign Banks Foreign Currency Income Taxes IRS Net Investment Income U.S. Treasury

FBAR Update

The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

1/29/2014 - Anti-Money Laundering Bank Secrecy Act Banking Sector FBAR FinCEN Foreign Banks Foreign Investment IRS Offshore Banks Offshore Funds Reporting Requirements

FBAR E-Filing and Signature Authority: What You Need to Know

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more

1/28/2014 - E-Filing FBAR Filing Requirements Foreign Banks Income Taxes IRS Offshore Banks Signatures Tax Evasion

The IRS and Gun Control

Earlier this month, the First Circuit Court of Appeals held in a case of first impression that evidence seized by IRS special agents from the taxpayer's home was admissible even though IRS Special Agents were armed when they...more

1/23/2014 - Conspiracies Fraud Gun Laws IRS Payroll Taxes Tax Evasion

Report Indicates Wealthy Chinese to Emigrate to US

Many foreigners crave United States citizenship even though it comes with corresponding obligations and responsibilities (i.e., think about tax compliance). CBS News previously wrote about pregnant women from foreign...more

1/23/2014 - Banking Sector China Citizenship Income Tax Treaty Income Taxes Reporting Requirements

Federal Court Rejects Efforts to Diminish Measures Aimed at Reducing Offshore Tax Avoidance

As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more

1/21/2014 - Banks Canada IRS Offshore Banks Tax Evasion

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