Informal surrender of Green Card doesn’t work
The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax...
View ArticleWhen do non-U.S. citizens pay income tax and report foreign financial accounts?
In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes. The report...
View ArticleWarning, Offshore Accounts Holders May Have No Fifth Amendment Protections
In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of...
View ArticleCheck Cashing, Tax Evasion, Structuring and Asset Forfeiture; The Making of a...
The following fact pattern should is representative of a tax evasion and structuring case. A taxpayer receives checks in the ordinary course of business from customers. Some of those checks are...
View ArticleJustice Department Focusing on Offshore Account
At a recent tax conference a senior Justice Department official reaffirmed thte commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official...
View ArticleWhat’s Next in Foreign Account Enforcement?
The Department of Justice and the IRS are now mining the wealth of data obtained through settlements (Non-Prosecution Agreements) with almost 100 Swiss banks. The search through the data is...
View ArticlePanama Papers To Be Released May 9, 2016. Why Does It Matter?
Panama Papers To Be Released May 9, 2016. Why Does It Matter? The International Consortium of Investigative Journalists (ICIJ) will release perhaps the largest database of private offshore companies...
View ArticleYou Skipped OVDP, now the IRS has initiated an Audit
Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income...
View ArticleForeign Bank Account Reports Due June 30
U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30....
View ArticleOffshore Enforcement Remains Top Priority of DOJ
PRINCIPAL DEPUTY ASSISTANT ATTORNEY GENERAL CAROLINE D. CIRAOLO DELIVERS REMARKS REGARDING THE TAX DIVISION’S OFFSHORE TAX ENFORCEMENT EFFORTS AT THE PANAMA BANKERS ASSOCIATION ANTI-MONEY-LAUNDERING...
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