April 2015

Streamlined Testimonial
Listen Dear Michael, Your excellent work on the streamlined procedure and related certification , and your explanations and discussions with me, were very much appreciated.  I am glad to have had the benefit of your experience and competence in completing the process. With every good wish, R.C.  
OVDP & Double Counting: Traps for the Unwary
Listen Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the …
Tax Planning on the Edge – Ride or Die in the International Tax Arena
Listen The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to …
OVDP And Double Counting: Oh The Agony! – Part II
Listen This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period. This is a simple example, yet it illustrates some of the common mistakes that are associated with …
A Message From Uncle Sam to Those With Foreign Assets: Don’t Forget Your U.S. Reporting Obligations
Listen On April 10, 2015, the IRS issued a press release entitled, “IRS Reminds Those with Foreign Assets of U.S. Tax Obligations.” I’ve attached the relevant portions below: WASHINGTON — The Internal Revenue Service  today reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or …