Charles (Chuck) Rubin – Gutter Chaves Josepher Rubin Forman Fleisher P.A.

2101 NW Corporate Blvd. Suite 107
Boca Raton, Florida 33431, United States

  • 561-998-7847

Applicable Federal Rates - August 2014

See Charts below for August 2014 Tax Rates…more
| Finance & Banking, Taxation

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures…more
| Finance & Banking, International Law & Trade, Taxation

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format (which…more
| Finance & Banking, International Law & Trade, Taxation

The IRS’ New 2014 Offshore Voluntary Disclosure Procedures (Part 1)

Last weekend I published the introduction to my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. Below is Part 1 of his 6 part…more
| Civil Procedure, Finance & Banking, International Law & Trade, Taxation

ITINs Will No Longer Expire After 5 Years (Sometimes)

Non-U.S. persons that need a taxpayer identification number must go through the onerous process of obtaining an international taxpayer identification number – commonly referred to as an ITIN…more
| International Law & Trade, Taxation

A Closer Look Into FBAR Late Payment And Interest Penalties Through The Zwerner Settlement – What Were The Penaties And Interest? - How Were They Computed?

While much about the Zwerner case (U.S. v. Zwerner, Case No. 13-22082-CIV, So. Dist. Fl.) has been discussed regarding the FBAR penalties, there has not been much attention paid to the 6% late payment penalty and interest…more
| Finance & Banking, International Law & Trade, Taxation

No Refund Of Extension Overpayment Followed By A Code §6166 Election

If an estate files to extend the due date of its Form 706 estate tax return, it can elect to defer the portion of the estimated estate tax that will be deferred pursuant to its Code §6166 election. It does not make the election…more
| Civil Procedure, Taxation, Wills, Trusts, & Estate Planning

Applicable Federal Rates – July 2014

Please see charts for more information…more
| Taxation

Employer Reimbursements For Health Insurance Policy Premiums–Care Needed

Employers who reimburse employees on a pre-tax basis for premiums the employees pay on their own individual health insurance policies (whether under an Obamacare Exchange or otherwise) are at risk for a $100 per day per employee…more
| Labor & Employment Law, Health, Taxation

Breaking OVDI News: 5% Streamlined Penalty Procedure Opened Up

In a major change to the Offshore Voluntary Disclosure Program, the streamlined filing compliance procedures with their 5% penalty, has been opened up to non-willful violators that reside in the U.S. This is to be contrasted…more
| Finance & Banking, International Law & Trade, Taxation

More On Inherited IRAs And Creditor Protection

Our post from yesterday discussed how the U.S. Supreme Court ruled in Clark v. Rameker that inherited IRAs are not exempt from creditor claims in bankruptcy. Here are some more observations on that case..…more
| Bankruptcy, Civil Procedure, Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

Inherited IRA Exposure To Creditors – Resolution At Last

We have written on the question whether inherited IRAs are exempt from creditors in a federal bankruptcy action. The various courts that have addressed the issue have gone in both directions…more
| Bankruptcy, Civil Procedure, Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

Time To Get Rid Of Your Circular 230 Disclaimer

Most tax practitioners tack on a Circular 230 disclaimer to their emails and other communications to avoid problems with reliance opinion and covered opinion provisions of Section 10.35 of that Circular. These disclaimers are…more
| Taxation

Online Poker Players Beware

I thought we had reached the end of our FBAR streak, but not yet. In a Federal District Court case opinion released last week, the Northern District of California ruled that a U.S. online gambler was obligated to report his…more
| Art, Entertainment, & Sports Law, Finance & Banking, International Law & Trade, Taxation

Bitcoins Do Not Require FBAR Filing

I have been posting a lot of FBAR-related posts lately. Here’s one more. There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting on…more
| Finance & Banking, International Law & Trade, Science, Computers, & Technology, Taxation
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Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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