August 2014

Should I Stay Or Should I Go? Fee To Renounce Citizenship Has Dramatically Increased By 422%
Listen Thinking about renouncing your citizenship? After reading this blog, you may want to think twice. Over the last two years, the number of U.S. expatriations has risen dramatically. While it might not be Ellis Island in reverse, it’s damn near close. What has caused people to resort to an option as drastic as renouncing …
Bankruptcy Fraud: A Little-Known Crime That Packs A Powerful Punch
Listen Bankruptcy fraud is a white-collar crime. It can occur in a variety of different ways. Violations run the gamut, from concealing assets, to intentionally falsifying forms, to filing or using inaccurate information of others, to bribing a trustee appointed by the courts. These actions usually occur in tandem with identity theft, mortgage fraud, money …
How Likely Is The IRS To Audit Me If I Quietly Disclose My Previously Unreported Offshore Account Pursuant To An Amended Return And A Delinquent FBAR?
Listen It is the most dreaded letter a taxpayer can receive. Dear Taxpayer, Some of the information that you provided to us does not agree with the information we received from other sources. — The Internal Revenue Service You’ve just joined an elite club, one whose initiation ritual is an IRS audit. Unfortunately, you can’t …
Beyond The FBAR: Other Civil Penalties Lying In Wait For The Unwary Taxpayer With Undisclosed Offshore Assets
Listen With all of the focus on FBAR penalties when it comes to foreign asset reporting, it’s easy to overlook the others, some of which can be just as onerous as the FBAR penalty itself. What other pestilent civil penalties are lying in wait for the unwary taxpayer who decides not to participate in one of the …
Man With Offshore Account Pleads Guilty To Hiding $ 1.1 Million From IRS
Listen An 83-year-old Florida man pleaded guilty this week to hiding at least $1.1 million from the IRS in secret Swiss and Israeli bank accounts for over a quarter century. Bernard Kramer held the secret accounts from 1987 to about 2012. He used the code phrase “Hot Lips” when referring to them in conversations with Swiss bankers in …
Does the IRS Have The Authority to Issue Whistleblower Awards For FBAR Penalties?
Listen Does the IRS have the authority to issue Whistleblower awards under Section 7623(b) to an individual who provides information that results in the assertion of FBAR penalties? In Whistleblower 22231-12W v. Commissioner, T.C. Memo. 2014-157, the Tax Court came close to deciding this issue. The only reason it stopped short was because the jurisdictional …
Mad As Hell And Not Going To Take It Anymore: Two Brave Women Sue Canadian Government Over Controversial FATCA Deal
Listen Is Ottawa violating Canadians’ constitutional rights to help the U.S. collect taxes? According to two Ontario women, it is. Two women are suing the Canadian government over a controversial deal in which Canada has agreed to share the tax information of U.S. persons who are Canadian residents with the IRS. On its face, the deal …
An Overview of the IRS’s Overhaul of OVDP And The Streamlined Procedures
Listen On June 18, 2014, the IRS announced sweeping changes to both the Streamlined and the OVDP programs. The effects are generally as follows: Streamlined Program – Opening the Program Up 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States; 2. Participants are not restricted to those …
Who Decides Whether To Authorize a Taxpayer’s Certification For Transitional Treatment To The Streamlined Procedures?
Listen Earlier this week, I spoke to an IRS Revenue Agent who shed some light on how the decision regarding transitional treatment is made for those taxpayers seeking to transition to the Streamlined Procedures from OVDP. Under the current procedures, the agent and his or her manager make the decision regarding transitional treatment, with involvement as …