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

By: Anthony N. Verni, Attorney at Law, CPA September 18, 2023 ©2023   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…

PROSECUTIONS FOR UNPAID EMPLOYMENT TAXES ON THE RISE

By: Anthony N. Verni, Attorney at Law/CPA AUGUST 5, 2023 @ 2023 PROSECUTIONS FOR UNPAID EMPLOYMENT TAXES ON THE RISE ARE YOU AT RISK? The assessment of the § 6672 penalty can be devastating, and in some cases, life changing. Individuals…

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

BY: ANTHONY N. VERNI, ATTORNEY AT LAW, CPA 08/05/2023 ©2023   FBAR PENALTY RELIEF FOR TAXPAYERS SUPREME COURT RULES NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM On February 28, 2023, in Bittner v United States, 598 U.S.…

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

Anthony N. Verni, Attorney at Law, CPA 09/05/2023 © 2023     SUPREME COURT TO DECIDE WHETHER MANDATORY REPATRIATION TAX IS CONSTITUTIONAL WITH RESPECT TO CFC UNDISTRIBUTED INCOME   On June 26, 2023 the Supreme…

ARE EMPLOYMENT TAX EXAMINATIONS BEING USED AS A PRETEXT FOR CRIMINAL PROSECUTION? 2022 ROUND UP

  Prosecution for employment tax crimes in 2022, reflects an increase in investigations for employment tax violations by the Department of Justice, Tax Division and also provides some insight as to the Government’s intention to prioritize…

FINAL RULE ISSUED UNDER THE CORPORATE TRANSPARENCY ACT IMPLICATIONS FOR THE SMALL BUSINESS OWNER

By: Anthony N. Verni, Attorney at Law, Certified Public Accountant November 4, 2022 © 2022   FINAL RULE ISSUED UNDER THE CORPORATE TRANSPARENCY ACT IMPLICATIONS FOR THE SMALL BUSINESS OWNER  The U.S. Department of the Treasury…
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AUDIT RISK TO INCREASE FOR LOW TO MIDDLE INCOME TAXPAYERS UNDER THE INFLATION REDUCTION ACT

By: Anthony N. Verni, Attorney at Law, Certified Public Accountant November 3, 2022 ©2022                                                                                              …
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FORM 5471 FILING REQUIREMENTS FOR U.S. TAXPAYER MARRIED TO NON-RESIDENT SPOUSE

  By: Anthony N. Verni, Attorney at Law, Certified Public Accountant Date: November 1, 2022 ©2022                                                                                    …
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FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS WHO HAVE FAILED TO FILE FORM 8938 AND FBARS

By:          Anthony N. Verni, Attorney at Law, Certified Public Accountant Date:     October 22, 2022 ©            2022   FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS…
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FIFTH CIRCUIT RULES NON-WILLFUL FBAR PENALTY IS PER ACCOUNT AND NOT PER FORM

The Fifth Circuit recently held in United States v. Bittner,  ___ F. 4th ___ (5th Cir. 11/30/21) that the non-willful FBAR penalty should be applied on a per account basis, rather than on a per form basis.  The Court cited 31 U.S.C. §5314…