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FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Indications of Misappropriation Schemes

Misappropriation is the use of property or funds of another person for an unauthorized purpose and is classified as a felony. In misappropriation, the perpetrator steals or misuses an organization’s belongings and resources;...more

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are...more

Is IRS really knocking at your door?

Generally, IRS sends a letter or a notice via regular mail notifying a Taxpayer of a potential visit. Nonetheless, IRS may also show up unannounced at the Taxpayer’s home or place of business....more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

Employee Business Expenses must be Ordinary and Necessary

Employees may be able to deduct their work related expenses as an itemized deduction. These expenses must be unreimbursed expenses that are ordinary and necessary to their work as an employee. According to IRS, an ordinary...more

Debit cards, Offshore Funds and a John Doe Summons

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

Colombia criminaliza la evasión fiscal

El 12/29/2016, el Congreso de Colombia aprobó la "Ley 1819 de 2016". La nueva legislación es una reforma tributaria estructural encaminada principalmente a aumentar los ingresos para Colombia....more

Colombia criminalizes Tax Evasion

On 12/29/2016, Colombia’s Congress approved “Law 1819 of 2016”. The new legislation is a structural tax reform primarily aimed at increasing revenues for Colombia. Colombia suffered a loss of revenues when crude oil...more

Is your Tax Preparer qualified to do your Return? Beware of Tax Preparers without a Preparer Tax Identification Number (PTIN) or...

Do you think that you have hired the right Tax Preparer to prepare your Taxes? Tax Season is here and many Tax Preparers portray themselves as “Qualified”. Tax Preparers have different levels of skills, education and...more

Tax Preparation is NOT a Commodity

As we approach this year’s tax filing deadline of April 18th, do you think that you have your Tax Return under control? Before you answer yes, take the time to examine and evaluate who is preparing your taxes. Do they have...more

The Value of Forensic Accounting Goes Beyond the Courtroom

Forensic Accountants play an integral role in the changing landscape of today’s business management and oversight. Successful business owners prepare for the possibility of malware attacks, internal fraud, lawsuits,...more

IRS will not Quit

Voluntary compliance is the foundation of our US tax system. Taxpayers determine the correct amount of their tax and complete appropriate returns, rather than the Government determine their tax for them. According to the...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

IRS Criminal Investigation Unit (IRS-CI) will find you!

Due to the Foreign Account Tax Compliance Act (FATCA) and the work of IRS special agents, international tax transparency is here. There is virtually nowhere to hide. On 1/18/17, the Department of Justice (DOJ) reported that...more

When the Wall of Secrecy Collapses

Foreign Accounts, Shell Companies, Blind Trusts, Asset Protection Trusts, Offshore Trusts, Global Citizenship and US Residency are just a few of the Terms highlighted in the mega divorce proceedings of a Palm Beach County...more

Do You Know What an IRS Criminal Investigation is?

The US taxes its citizens and permanent residents on their worldwide income regardless of where they live or how long they’ve lived outside of the US. There is only one other country in the world that operates like the US –...more

How A Defendant Won The Lottery!

The decision to hire a Forensic Accountant can be like buying a lottery ticket. Not all Forensic Accountants are equal. Not all possess the characteristics and critical success factors of an effective Forensic Accountant,...more

Are Forensic Accountants an Attorney’s Silver Bullet?

From the art of interviewing, to recognizing mathematical irregularities, and following the money, Forensic Accountants are a proven invaluable tool for Attorneys and their clients. “Finding” the money combines the skill...more

FBI Is Focused On Professional Service Providers

James C. Barnacle, Chief of the Money Laundering Unit in the Financial Crimes Section, Criminal Investigation Division, of the FBI recently stated that there is a RENEWED emphasis on investigations targeting “ money...more

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

¿Sabe usted el propósito de los Procedimientos de Presentación de Cumplimiento Racionalizados?

Procedimientos Racionalizados de Presentación de Cumplimiento (Streamlined Filing Compliance Procedures) es una de las opciones disponibles para los contribuyentes Estadounidenses con activos e ingresos financieros...more

Do you know the purpose of the Streamlined Filing Compliance Procedures?

Streamlined Filing Compliance Procedures (Streamlined) is one of the options available for US Taxpayers with unreported foreign financial assets and income. It is intended for the Taxpayers that have acted non-willfully. ...more

¿Sabe usted por qué y cómo entrar en el Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP)?

A través del Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP – Offshore Voluntary Disclosure Program), el IRS permite a los Contribuyentes que no están en cumplimiento intentionalmente revelar las cuentas...more

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