eBook | Foreign Asset Reporting: Navigating the Choppy Financial Seas.

Understanding the PFIC Rules Without Suffering a Migraine

I would not be honest if I didn’t admit that this was a topic that I have procrastinated writing about for the longest time and have avoided like the Bubonic plague. It is such a tortured area of foreign asset reporting that many tax practitioners refer to it as, “a riddle wrapped in a mystery […]

Lifting the Veil on the Civil FBAR Penalty

It should come as no surprise that the IRS has authority to assess FBAR civil penalties.  However, what might come as a surprise is that an FBAR violation doesn’t automatically mean that a penalty will be asserted.  Why not?  Examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, […]

No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts

United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time during […]

Don’t Get Snared in Any of the Three Stages of Money-Laundering

“Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities.”…U.S. Department of Treasury Website Law enforcement and financial regulators everywhere are on the lookout for money laundering. Big corporations and financial institutions hire compliance experts, and those experts cooperate fully […]

Liens and Levies Make the IRS a Collection Agency on Steroids

Sometimes the problem with “food for thought” is that it can almost choke you with its stark simplicity. Take our tax system, for example. The federal government prints our money, regulates the places where we keep it and has vast powers to take it away from us if we don’t give them their cut. The […]

White Collar Crime: Entrapment and Ignorance of the Law Can Snare the Unwary

The most common white-collar offenses run the gamut of nonviolent crimes from antitrust violations to money laundering. The FBI estimates that white-collar crime costs the United States more than $300 billion annually. These estimates do not take into account cases where aggressive and ambitious prosecutors snare an unwary person, who eventually pleads guilty in the […]

Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS

In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions. FATCA is an attempt by the IRS to “improve reporting compliance” — translation: “widen the net” […]

Even With a DUI Charge You Are Innocent Until Proven Guilty

If you believe the conventional wisdom, when you are stopped by the police and placed under arrest for driving under the influence, you have already been found guilty. You are not guilty, and the state has a heavier burden of proof than you might imagine. Take a look at the State of New Jersey Motor […]

IRS Due Process Collections — Placing a Velvet Glove on the Wrecking Ball

Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed. Said due process […]

Manco and Manco Owners Arrested on Charges of Tax Evasion

The owners of Manco and Manco Pizza, an Ocean City Boardwalk mainstay, were arrested Thursday, April 3 on federal tax evasion charges. According to the US Attorney’s Office, Mary, 53, and Charles Bangle, 54, were arrested in their Somers Point home by IRS-Criminal Investigation special agents on an indictment charging the couple with multiple counts […]