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Fraudulent Tax Resolution Co.
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Fraudulent Tax Resolution Companies

Promises Too Good To Be True In 1931, the famous jurist, Benjamin Nathan Cardozo, in discussing fraud stated that: “Fraud is the pretense of knowledge when knowledge there is none.” Ultramares Corp. v. Touche, 255 N.Y. 170, 179, 174 N.E.…
Tax cut and Jobs Act

Divorce Tax Rule Changes

New rules in Tax Cuts and Jobs Act  With the enactment of the Tax Cuts and Jobs Act (“TCJA”), divorce attorneys and those that are divorced, in the process of divorce or who have a pre or post nuptial agreement should familiarize themselves…
E File form8300
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IRS Urges Businesses To E-File Cash Transaction Reports

Electronic Filing For Businesses In an effort to promote compliance, on February 19, 2019 the IRS urged businesses that are required to file reports of large cash transactions to take advantage of the electronic filing option that was announced…
Ghost tax preparers
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IRS warns against using Ghost Tax preparers

Large Tax Refunds: Are they too good to be true? The IRS has long cautioned taxpayers against using disreputable tax return preparers. In a recent announcement, the IRS warned taxpayers against using “Ghost Preparers” to prepare their tax…
New OVDP
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New Voluntary Disclosure Practice for willful u.s. taxpayers

 Termination of OVDP and way forward Following the termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018, willfully delinquent taxpayers with exposure to criminal prosecution were left without an option for…
Deliquent Expat Filers and Facilitators 1

Delinquent Expat Filers and Facilitators: Are you in Trouble?

Introduction Expatriates (Expats) who continue to ignore their obligations to file U.S. Federal Income Tax returns and who fail to report their foreign financial accounts as well as those who fail to file information returns with respect…
Trust fund recovery penalty
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Trust Fund Recovery Penalty

The Trust Fund Recovery Penalty: Are You At Risk? Introduction 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…
FBAR
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Willful FBAR penalty Case Study.

 Wilfull FBAR Penalty. The following is intended as an update to my January 26, 2019 Blog on the subject of the limitation of the willful FBAR (Foreign bank Account Report) penalty under United States v. Colliot, 2018 U.S. Dist. LEXIS 83159…
OVDP Lawyer
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Streamline Disclosures- The Art of the Non-Willful Certification.

Offshore disclosure to IRS. The key to making an offshore disclosure to the IRS using either the Domestic or Foreign Filing Compliance procedures requires a thorough and painstaking analysis of the facts involving an individual’s failure…
FBAR
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The Willful FBAR Penalty: Is it Limited to $100,000? Not so Fast.

 Assessment of FBAR penalty Some practitioners have applauded the decision in United States v. Colliot, 2018 U.S. Dist. LEXIS 83159 (W.D. Tex. 2018) and have even suggested that the assessment of the willful FBAR penalty is limited to…