An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program..…more
An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program..…more
Taxpayer’s often find themselves facing substantial penalties for failing to file or late payment of income estate or gift tax return. Some taxpayers face enormous penalties for failing to file a Report of Foreign Bank or…more
The Criminal Tax Division of the U.S. Dept of Justice (DOJ)is taking the position that when a taxpayer has “willfully” failed to file a Report of Foreign Bank or Financial Account, an FBAR, and has in addition filed false income…more
June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control…more
In what is clearly the first of many to come intergovernmental agreements similar to the Foreign Account Tax Compliance Acct (FATCA) adopted by the U.S. in 2010, the governments of Switzerland and the United Kingdom entered into…more
A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients…more
“Sometimes for taxpayers, who have serious tax non-compliance issues or may be facing international tax enforcement, the option of initiating a state voluntary disclosure contemporaneously with the making of a federal voluntary…more
Recently, two Israeli banks are reported to have agreed to cooperate in criminal tax investigations being conducted by the Criminal Tax Division of the U.S. Department of Justice. The specific actions allegedly involve a…more
The following summarizes in explicit detail why taxpayers who have an unfilled Report of Foreign Financial or Bank Account (FBAR) must consider entering the Offshore Voluntary Disclosure Program (OVDP). Not only does the…more
Some taxpayer’s who think that they have properly relied on the advice of professionals and should therefore be able to avoid FBAR penalties need to consider what constitutes “reasonable cause”. First, the reasonable cause cases…more
EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows..…more
A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the…more
For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return in…more
Recently the Acting IRS Commissioner said:
“While successful implementation of the Foreign Account Tax Compliance Act will assist the IRS in pursuing tax evaders, it is not the government’s sole answer to the long-term…more
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