News & Analysis as of

Statute of Limitations Foreign Bank Account Report

Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period... more +
Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period usually commencing from the date of the wrong or injury or the discovery of the wrong or injury. Except for under a limited set of circumstances, if an individual does not file a suit within the specified time period, the law bars them from ever suing on that claim. less -
Allen Barron, Inc.

Tax Updates and Information for US Expatriates

Allen Barron, Inc. on

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

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on

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

Cole Schotz

Supreme Court Rules Non-Willful FBAR Penalties are Calculated on a Per Report Basis

Cole Schotz on

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

Freeman Law

Everything That You Need To Know About International Tax Penalties

Freeman Law on

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

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

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

Morgan Lewis

Highway Funding Bill Includes Significant Changes to Tax Rules

Morgan Lewis on

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

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