Tax Fraud And Denaturalization Risks: A Balanced View For Taxpayers

Recent headlines have created alarming concerns among naturalized U.S. citizens. These have suggested that certain tax issues could lead to the loss of U.S. citizenship. This fear is now being amplified on various platforms and stems from a case involving, Vanessa Ben, a Houston woman facing denaturalization over her admission of tax fraud prior to … Continue reading Tax Fraud And Denaturalization Risks: A Balanced View For Taxpayers →

BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud

Roger Ver, an early bitcoin investor (from approximately 2011) also known as “Bitcoin Jesus,” was just arrested in Spain based on US criminal charges. According to the indictment filed February 15, 2024 but recently unsealed, Ver has been charged with mail fraud, tax evasion, and filing false tax returns. Ver was a former US citizen who … Continue reading BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud →

IRS Voluntary Disclosure Practice and Closing Agreement: Understanding the Basics

The Internal Revenue Service (IRS) Voluntary Disclosure Practice (VDP) is alive and well. Its parameters are set out in Internal Revenue Manual (IRM) provisions dedicated strictly to the VDP. IRM 9.5.11.9.1 Voluntary Disclosure Practice, is available here. Under the VDP, the nature and extent of penalties to be assessed against a taxpayer will, to a … Continue reading IRS Voluntary Disclosure Practice and Closing Agreement: Understanding the Basics →

Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date. The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way →

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 →