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Self Employed Tax Schemes That Always Fail

If you are self-employed and recently received an examination notice from the Internal Revenue Service or are have concerns about the manner in which you have been operating your business, you may find the following discussion helpful. For…
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Unfiled Income Tax Returns “Come Into The Light”.

Serial Tax Return Non-filers. Every year, thousands of individuals fail to file their Federal and State Income Tax returns despite being required to do so. I refer to these individuals as “serial non-filers,” since many of these individuals…
Folder tabs with focus on offshore account tab. Business concept image for illustration of tax evasion.

Kenyans to Disclose Offshore Income and Assets or Face Stiff Penalties.

Global Tax Initiatives and Kenya. Kenya Revenue Authority (KRA) has thrown down the gauntlet, advising Kenyans who are working overseas that failed to take advantage of Kenya’s tax amnesty program that they will now face stiff penalties.…
The Foreign Bank Account Report (FBAR) can be submitted with the advice of a tax law attorney.
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Willful FBAR Penalty- Legal Decisions Diminish Taxpayer Prospects for Successful Defense.

Case Facts. April 3, 2018, the U.S. District Court in United States v. Garrity held that, for purposes of the assessment of the Willful FBAR penalty, the Government’s burden of proof is a “preponderance of evidence,” rather than the higher…
FBAR
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The Non-willful FBAR Penalty and the Slow Death of Reasonable Cause.

Non Willful FBAR Penalty Ruling. A December 2017 decision of the Court of Federal Claims in Jarnagin v. United States begs the question: Whether a Taxpayer can ever have a reasonable cause defense to the assessment of the Non-Willful FBAR Penalty.…
Tax Returns and Deportation 1
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Immigration and Lying on your Tax Return: The Quickest way to deportation.

Lying on tax return as an immigrant. The IRS has identified a rise in the number of immigrants who routinely lie on their tax returns in order to secure large refunds to which they are not entitled. To address this trend, the IRS has vowed…
Offshore Voluntary Disclosure Program
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OVDP Coming to an End Soon

Internal Revenue Service plans to close the Offshore Voluntary Disclosure Program (OVDP) on September 18, 2018. The Internal Revenue Service recently announced that they will be winding down the Offshore Voluntary Disclosure Program (OVDP)…
If you have been contacted by the IRS concerning your business expenses and the losses reflected on your Federal income tax returns, you should contact a competent tax attorney
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Case Where Texas Ranchers Were Victorious in IRS Appeal

Dallas Appeals Officer Reverses IRS Decision Allows Business Expenses and Ranching Losses for 2011 & 2012 and Abates the 20% Accuracy Related Penalty Back in 2014, I represented a Texas couple in connection with an Appeal from an IRS decision…
FBAR statute of limitations can incur FBAR penalties by the IRS, here is a prior experience with a New Jersey couple
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New Jersey Couple Avoids FBAR Penalty and Instead Receives Warning Letter

The following is an actual FBAR case handled by the Law Office of Anthony N. Verni. My Princeton New Jersey office was successful in securing a waiver of the proposed FBAR penalties for these two taxpayers. Mr.and Mrs. Beránek (a.k.a. the…
Offshore Tax Compliance Update fbar penalties for tax evasion can include imprisionment if the IRS seeks to criminally prosecute you

Tax Attorney Sentenced To 48 Months For Employment Tax Fraud

Pittsburgh Tax Attorney Gets 48 Months For Employment Tax Fraud On January 12, 2017 Steven Lynch, a Pittsburgh tax attorney, was sentenced to 48 months in prison,following his conviction for the willful failure to pay over payroll taxes (Trust…