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Eleventh Circuit Sustains Willful FBAR Penalty, But throws the Taxpayer a Bone

By: Anthony N. Verni Attorney at Law, CPA September 5, 2024 ©2024   Eleventh Circuit Sustains Willful FBAR Penalty, But throws the Taxpayer a Bone On September 4, 2024, the United States Court of Appeals for the 11th Circuit in…
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EMPLOYMENT TAX AUDITS ON THE RISE SECTION 6672 PENALTY AND CRIMINAL PROSECUTION

By: Anthony N. Verni, Attorney at Law, CPA August 13, 2024 ®2024 EMPLOYMENT TAX AUDITS ON THE RISE SECTION 6672 PENALTY AND CRIMINAL PROSECUTION Employment tax audits are on the rise and so too is the exposure to those individuals …
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TAXPAYER’S PERSONAL CRISIS NO DEFENSE TO WILLFUL FBAR PENALTY

By: Anthony N. Verni, Attorney at Law, CPA August 13, 2024 ©2024   TAXPAYER’S ADHD DIAGNOSIS, STRESS, DEPRESSION AND STAGE 3 PROSTRATE CANCER NO DEFENSE TO WILLFUL FBAR PENALTY   On August 6, 2024 the U.S. District Court for…
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THAI RESIDENTS MUST NOW PAY THAI INCOME TAX ON FOREIGN SOURCE INCOME

The Thai Revenue Department recently issued Order No. 16/2023 (the “Order”), which marks a significant shift in Thai tax policy as it relates to Thai Residents, who derive income from foreign sources or own offshore assets. The Order, which…
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LARGE TAX REFUNDS AND THE GHOST PREPARER

Earlier this year a Charlotte man was charged with tax fraud in a 20 count criminal indictment, charging him with aiding and assisting in the preparation and filing of false returns over a five year period. According to the allegations, between…
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FBAR PROSECUTIONS-FORMER CFO SENTENCED TO EIGHTY SIX MONTHS IN PRISON

On September 21, 2023 a  former CFO of  a Russian natural gas company was sentenced to seven years in prison, ordered to pay $4 million dollars in restitution and an additional $350,000 in fines in connection with a number of tax and financial…

WHAT DO OFFERS IN COMPROMISE AND ALUMINUM SIDING HAVE IN COMMON?

After many years, I decided to watch Tin Men again. It is a 1987 movie starring Danny DeVito and Richard Dreyfuss, both of whom are aluminum siding salesman in Baltimore in the late sixties.  They run  multiple scams, including “Life Magazine”…

PROSECUTIONS FOR UNPAID EMPLOYMENT TAXES ON THE RISE

The assessment of the § 6672 penalty can be devastating, and in some cases, life changing. Individuals who are subject to the penalty usually state that they were unaware that failure to collect and pay employment taxes to the IRS could result…

FBAR PENALTY RELIEF FOR TAXPAYERS. NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM

On February 28, 2023, in Bittner v United States, 598 U.S. (2023) the U.S. Supreme Court, in a five to four decision, ruled that the non-willful FBAR penalty should be assessed per form rather than per account. The decision settles the inconsistent…

SUPREME COURT TO DECIDE WHETHER MANDATORY REPATRIATION TAX IS CONSTITUTIONAL WITH RESPECT TO CFC UNDISTRIBUTED INCOME

On June 26, 2023 the Supreme Court granted the Petitioners’ Application for a Writ of Certiorari for purposes of considering the constitutionality of the Mandatory Repatriation Tax as it pertains to U.S. Shareholders in a Controlled Foreign…