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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…
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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)…