IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”).  My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”.  In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Is the IRS Trying to Find You?

Moving is always a stressful event and it is easy for certain things to be overlooked. One item on your moving checklist that is critical to remember: properly notifying the Internal Revenue Service (IRS) of your change of address.  Today's post tells you how to do it right and the terrible things that can happen … Continue reading Is the IRS Trying to Find You?

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!

Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008.  The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

IRS Website = Unreliable, Legal Weight = Zilch

The stress of tax filing time had been on full throttle in April, and taxpayers abroad were scrambling to meet the tax filing deadline in June ... many taxpayers are on extension until October.  Here's a familiar scenario: You need to find an answer to a tax question and turn to your good friend, Mr. … Continue reading IRS Website = Unreliable, Legal Weight = Zilch

Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!

Most of my readers are aware of the “attorney-client privilege”. Generally speaking, the privilege preserves the confidentiality of communications between a lawyer and her clients.  When the privilege is in place, attorneys may not divulge their clients’ secrets and cannot be "forced" to divulge them (for example, in a court proceeding or to the Internal … Continue reading Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!

SHUTDOWN… Last IRS Agent to Leave, Please Turn off the Lights

For those of you who have been sleeping too much the past few days, let’s wake up and learn a bit about the face-off in Washington DC over the border security wall. Right now, there’s no federal budget in place and funding for many government agencies has disappeared, resulting in partial shutdowns for some, including … Continue reading SHUTDOWN… Last IRS Agent to Leave, Please Turn off the Lights

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

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”