Resources

You are here: / Resources
  • tax law articles
  • resources for
  • tax law resources
123

Legal Resources

The best place for expatriates to find tax law resources.

Read our Blog

 Get the latest news and the most advanced industry knowledge.

FBAR Quiet disclosures

FBAR CONSENT TO EXTEND STATUTE OF LIMITATIONS OPERATES AS A WAIVER/NON WILLFUL FBAR PENALTIES ASSESSED PER ACCOUNT

U.S. DISTRICT COURT DECIDES FBAR PENALTY STATUTE OF LIMITATIONS WAIVED AND  ASSESMENT OF NON WILLFUL FBAR PENALTIES PER ACCOUNT The U.S. District Court for the Southern District of Florida recently held that the statute of limitations for…
FBAR Quiet disclosures
, , ,

Quiet Disclosures and the Civil Willful FBAR Penalty. Even Death Will Not Help You

The Government will examine efforts by a Taxpayer to avoid detection by the Internal Revenue Service, when deciding whether to assess the Civil Willful FBAR penalty. In particular, the IRS considers  making a quiet disclosure, an indicator…
FBAR Quiet disclosures
, ,

HOW BIDEN’S TAX PROPOSAL WILL IMPACT GIFT AND ESTATE TAX PLANNING

The Biden Tax Proposal, if enacted, will have a significant impact on estate planning for those who have failed to take advantage of the current gift and estate tax rules.  According to the Proposal, estate and gift tax exemption will be reduced…
Tax fraud
, ,

TRANSFERRING PROPERTY TO AVOID PAYING TAXES

Why it's a Very Bad Idea? A taxpayer who owes or anticipates owing a substantial amount of income tax to the IRS may be tempted to transfer his or her property to a spouse, a relative or a nominee entity with the hope of preventing the IRS…
Statue of limitation

UNDERSTANDING THE STATUTUE OF LIMITATIONS

Duration the IRS Has to Assess Federal Income Tax? The statute of limitation for assessment purposes represents the last day in which the Internal Revenue Service may assess federal income tax. The statute of limitations for assessment should…
Income Tax Systems

INCOME TAX SYSTEMS

Understanding Global Income Tax Systems Understanding how and when the United States imposes federal income tax on its U.S. Tax Residents in cross border transactions has long been a source of confusion to U.S. taxpayers. In fact, in some cases,…
Financial crimes
,

Former Harvard Chemistry Chair indicted for failing to file FBAR and filing false tax returns

IRS Hard at Work Despite the Pandemic Individuals, who have failed to report their foreign financial accounts, may feel a sense of relief, in light of the corona virus and its effects on IRS investigations. Better think again! The DOJ recently…
FBAR non willful penalty dilemma
,

Courts Split on FBAR non-willful Penalty

Should FBAR non-willful penalty be charged per form or per account? The Courts have recently addressed the issue of whether the FBAR Non-Willful penalty should be assessed per form rather than per account with conflicting results.  InUnited…
Cash Intensive Business and the IRS

Cash Intensive Businesses & the IRS; a marriage made in Hell

Cash intensive businesses Operating a cash intensive business is often accompanied by poor record keeping as well as the lack of any meaningful internal controls. These two factors make it difficult, if not impossible, to determine the taxpayer’s…
FBAR Quiet disclosures
, ,

Quiet Disclosure Guilty Plea

Florida man pleads guilty to tax evasion and hiding funds around the world In April 2020, a Florida man pleaded guilty to tax evasion and the willful failure to file FBAR’s. What makes this case particularly interesting is that the taxpayer…