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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…
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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…
income tax return due date.jpg thump
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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…