The Unreported Offshore Account – Still Alive After Death & Plaguing Executors and Heirs

My blog post reproduced below was originally posted on AngloInfo "Let's Talk About US Tax" Posted on October 12, 2015 by Virginia La Torre Jeker J.D., When someone dies owning an unreported financial account, the heirs and executors of the estate are faced with a serious problem. First, assuming there is undeclared income earned with respect to the … Continue reading The Unreported Offshore Account – Still Alive After Death & Plaguing Executors and Heirs →

Reminder – All About Alimony and the Foreign Spouse….If You Hate Your Spouse As Much as You Hate Paying Taxes …

My readers know that broad US tax reform was enacted in December under the commonly called Tax Cuts and Jobs Act (“TCJA”). Today’s post is a reminder of how the new tax rules will impact any US spouse who will be either paying or receiving alimony. The clock is ticking and action must be taken … Continue reading Reminder – All About Alimony and the Foreign Spouse….If You Hate Your Spouse As Much as You Hate Paying Taxes … →

Jail Time for Plastic Surgeon Hiding Money in Dubai

This FBAR case hit close to home. In fact, it hit home! The Department of Justice proudly announced that it flushed out a Beverly Hills plastic surgeon hiding money in Dubai and got him sentenced to one year and one day in federal prison. Marc Edward Mani, 50, will serve jail time for failing to … Continue reading Jail Time for Plastic Surgeon Hiding Money in Dubai →

FBAR “Last Chance” Due Date Soon Here – What to do with Virtual Currency?

The Financial Crimes Enforcement Network (FinCEN) had earlier issued an announcement reminding of the due date for filing the 2017 FinCEN Form 114, Report of Foreign Bank and Financial Accounts (the notorious “FBAR”). The 2017 FBAR relates to foreign financial accounts held at any time during the calendar year 2017. In line with the change in … Continue reading FBAR “Last Chance” Due Date Soon Here – What to do with Virtual Currency? →

Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles

Do I have to pay tax on that? Get the full scoop in today's post! “Expat” taxpayers living abroad are often given certain perks from their employers that would not be provided if the individual remained State-side. For example, provision by the employer for airline tickets home for the taxpayer and his/her family; or payment … Continue reading Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles →

The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Two courts have limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did not update the relevant regulations to match the statute as revised by Congress in 2004. Essentially the dispute … Continue reading The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance →

Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000

Another court just slammed the Internal Revenue Service (IRS), limiting the “willful” FBAR penalty to $100,000. Another taxpayer victory took place last week in United States v. Wadhan, (Civil Action No. 17-CV-1287-MSK District Court, District of Colorado July 18, 2018). The Wadhan’s failed to file or filed inaccurate so-called FBARs for 2008, 2009, and 2010. … Continue reading Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000 →

Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty

The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS). The case was initiated by the US Government to reduce to judgment outstanding civil penalties assessed against Ms. Colliot for her “repeated and willful failures to timely file” an FBAR for the … Continue reading Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty →

FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge”

I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating that a taxpayer “willfully” failed to file an FBAR. The “burden of proof” refers to which party is responsible for putting forth evidence and, the level of evidence … Continue reading FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge” →

Form 1040: Similar to a Postcard, But …With (LONG) Letters Attached

Looks to me like the Internal Revenue Service (IRS) is doing the “shuffle”! The draft Form 1040 for 2018 certainly looks shorter, but closer inspection shows the IRS is merely shuffling the workload onto Schedules. Right now, the IRS is very busy keeping pace with the changes wrought by the Tax Cuts & Jobs Act … Continue reading Form 1040: Similar to a Postcard, But …With (LONG) Letters Attached →