Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more
Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more
On February 15, 2022, the IRS announced that IRS Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, and the accompanying instructions to the form had been revised. Because the revisions provide...more
The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more
For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
1/14/2022
/ Estate Planning ,
Foreign Trusts ,
Grantor Trusts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Amnesty ,
Tax Evasion ,
Tax Planning ,
Tax Returns ,
Voluntary Disclosure
This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more
1/6/2022
/ FBAR ,
FOIA ,
GAO ,
Income Taxes ,
International Tax Issues ,
IRS ,
Offshore Funds ,
OVDP ,
Retirement Plan ,
Revenue Procedures ,
Tax Evasion ,
Tax Planning ,
Voluntary Disclosure