Cryptocurrency – Criminal Investigations have Commenced!

First, a special thank you to Steve Phillips, a tax & business lawyer in Texas, who alerted me to this recent development. According to an Internal Revenue Service (IRS) special agent, Mr. Chris Hueston, the IRS has now officially begun investigations into tax evasion and other crimes tied to cryptocurrency. The announcement made on November … Continue reading Cryptocurrency – Criminal Investigations have Commenced!

Passport Non-Issuance/Revocation: A Welcome Reprieve for Some Tax Debtors

On August 8th, the Internal Revenue Service (IRS) reminded taxpayers with “seriously delinquent tax debt” that they can lose their US passports. I will provide more detail on this below, but first, the “good news”.  It was announced on August 14, 2019 that Charles Rettig, the IRS Commissioner, has granted a reprieve for some tax debtors … Continue reading Passport Non-Issuance/Revocation: A Welcome Reprieve for Some Tax Debtors

Did you Join OVDP? You’d Better Still be in Tax Compliance!

The Internal Revenue Service (IRS) has now expanded its compliance campaigns and included “post Offshore Voluntary Disclosure Program compliance” on the list. On July 19th, the IRS through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets taxpayers who had entered an Offshore Voluntary Disclosure Program (OVDP) … Continue reading Did you Join OVDP? You’d Better Still be in Tax Compliance!

A Dangerous Game: Jail Time for Inherited Foreign Accounts

You may remember my earlier blog post detailing the unenviable case of the wealthy New York Seggerman family which had undisclosed offshore bank accounts inherited from their father. Instead of coming clean and revealing the existence of the accounts to the US Internal Revenue Service (IRS), four of the Seggerman siblings created even more secret … Continue reading A Dangerous Game: Jail Time for Inherited Foreign Accounts

Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

Americans in Dubai / Singapore – If you are not tax compliant, time is really running out.  As reported by Bloomberg on March 8th, an official with the Internal Revenue Service (IRS) Criminal Investigation (CI) unit announced at a Washington DC Federal Bar Association event that CI is considering Dubai and Singapore as its "next … Continue reading Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

It’s Finally Here: The IRS Bible for Voluntary Disclosures

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28th with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance just arrived in the form of a 5-page Memorandum by Kristen B. Wielobob, Deputy Commissioner for Services and Enforcement, … Continue reading It’s Finally Here: The IRS Bible for Voluntary Disclosures

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

OVDP Ending / IRS To Announce New Procedures

The Internal Revenue Service (IRS) reminded taxpayers yesterday that they have until September 28 to apply for the Offshore Voluntary Disclosure Program (OVDP). In March, the IRS announced the program would end on the 28th of this month. The IRS has made clear that it will continue to hold taxpayers with undisclosed offshore holdings accountable after … Continue reading OVDP Ending / IRS To Announce New Procedures

Tax Primer: US Expats & Foreigners

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Everything you need to know about US tax is right here at your fingertips!  My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners

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”