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IRS Issues Updated Guidance for FBAR Penalties

The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17. For those […]

What If …

Having trouble viewing this email?Click here WEBSITE FIRM OVERVIEW ATTORNEYS TAX SEMINARS TAX CHAT CONTACT   May 19, 2015  The White Knight Chronicles   What If …   What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and […]

What Happens in Vegas Stays in Vegas

The catch phrase in the movie Jerry McGuire was “Show Me the Money!” It now looks like prosecutors are adopting the same mantra and are enjoying success in courts indicting those that attempt to hide money and avoid paying taxes either in the U.S. or abroad. In the past, it was a given that an […]

What If …

What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and anything else, that happened to be there at the time? Would they still be lounging in the Garden of Eden today, munching on pomegranates and perusing through […]

IRS Updates Rules For Foreign LLC’s

The IRS recently updated its rules for foreign LLC’s. The updates can be found here. The relevant portions are contained below: A Limited Liability Company (LLC) is a business structure allowed by state statute. Each state may use different regulations, and you should check with your state if you are interested in starting a Limited Liability […]

From Convicted Felon to Government-Made Millionaire: The Man Who Ended the Tradition of Bank Secrecy and Got Rich in the Process

Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little did […]