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…
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…
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…
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
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,…
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…
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 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…