Category: Offshore Voluntary Disclosure

Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!

Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews! →

WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!

Learn all about FBAR and expand services to your clients with confidence.  Maybe even land Pope Leo XIV as a new client since his Holiness probably has to file FinCEN Form 114 for the Vatican Bank's accounts.  Understand your own compliance risks and what to do if you are not compliant.  This is the FBAR … Continue reading WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR! →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

The Scary Truth About Navigating IRS Tax Guidance

My article is copied in full below. It first appeared on Forbes July 24, 2024 – link here.  You can follow me on Forbes for free.   Imagine this: You have a pressing tax question and, like many, you turn to Google. Among the plethora of results, you spot information from the IRS, including its … Continue reading The Scary Truth About Navigating IRS Tax Guidance →

Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties 

As predicted, the fallout from the United States Supreme Court decision in Bittner v. United States, means a tougher stance by the Internal Revenue Service (IRS) when it comes to reducing so-called “FBAR” penalties for “nonwillful” violations.  In a nutshell, the Bittner court held that the Bank Secrecy Act (BSA) $10,000 maximum penalty for the … Continue reading Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties  →

BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account

What we have all been waiting for!  Bittner v. United States was just decided hours ago by the United States Supreme Court! An amazing taxpayer win.  It is late here in the Middle East, so I provide only the information you need to know!  You can read the full case here. The Bank Secrecy Act … Continue reading BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account →

Mr. FBAR Gets Bolder in Toth – “Deemed Willfulness” for FBAR Violation

Today’s blog post looks again at the Report of Foreign Financial Accounts (Form 114), the well-known “FBAR”.  It examines a case of first impression when it comes to finding a “willful” FBAR violation. Before delving into the case, I provide readers with a quick introduction to Mr. FBAR. The FBAR has its genesis in the … Continue reading Mr. FBAR Gets Bolder in Toth – “Deemed Willfulness” for FBAR Violation →

Breaking! Gird Your Loins for Greater FBAR Penalties! Supreme Court Denies Review in Toth/ Excessive Fines Issue

United States v. Toth:  Just yesterday, the United States Supreme Court denied review of Toth, a case being carefully followed by tax professionals who deal with FBAR cases, US persons abroad, and all things "foreign". Toth was an FBAR “willful” penalty case on appeal to the First Circuit, with one of the issues being whether … Continue reading Breaking! Gird Your Loins for Greater FBAR Penalties! Supreme Court Denies Review in Toth/ Excessive Fines Issue →

Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US

The Taxpayer Advocate Service (TAS) recently released its 2022 report to Congress.  In one portion of the Report (listed in “Most Serious Problems Encountered by Taxpayers” #10 OVERSEAS TAXPAYERS: Taxpayers Outside of the United States Face Significant Barriers to Meeting Their U.S. Tax Obligations) TAS provided a succinct review of the problems faced by American … Continue reading Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US →

What is a Closing Agreement and When Will One Be Entered Into by the IRS?

Last week's blog post, here, discussed the details of the Internal Revenue Service "Voluntary Disclosure Practice" (VDP).  VDP is the one and only method for voluntary disclosures that apply to criminal tax activity, regardless if the activity involves offshore issues or strictly domestic ones.  The final conclusion of a taxpayer’s entry into the Voluntary Disclosure … Continue reading What is a Closing Agreement and When Will One Be Entered Into by the IRS? →