US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more
On February 28, 2023, in a significant tax case, Bittner v. US, the U.S. Supreme Court held that a U.S. person who fails to file his or her FBAR on a non-willful basis only is subject to a single penalty on the failure to...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more
Unexpected changes in FBAR, corporate and partnership returns, and statute of limitations and mortgage reporting tax rules are embedded in funding bill H.R. 3236. When US President Barack Obama extended funding for...more