OVDI: Is the IRS Playing Fair?
A Message From Uncle Sam to Taxpayers Who Have Undisclosed Foreign Bank Accounts: The Clock Is Ticking Since 2009, the IRS has offered taxpayers with undisclosed foreign financial accounts the opportunity to “come clean” under its Offshore Voluntary Disclosure Initiative (OVDI). According to the IRS, more than 38,000 U.S. taxpayers have entered the program. They […]
UNDERSTANDING THE SOURCE OF INTEREST RULE WITHOUT SUFFERING A MIGRAINE
As a general rule, interest paid by individuals, partnerships, and trusts takes its source from their place of residence. A natural corollary to this rule is that interest paid by individuals, partnerships, and trusts that are “residents” of the United States has U.S. source. This source rule has consequences that both borrowers and lenders will […]
Kat Jennings, CEO TaxConnections
Michael DeBlis is an extraordinary Tax Attorney who brings the knowledge, experience and passion required to protect his clients. It is rare to find a Tax Attorney who has these skills inside and outside the courtroom. Kat Jennings, CEO TaxConnections
IS THAT WORKER AN EMPLOYEE? QUESTIONS AND ANSWERS ON WORKER CLASSIFICATION
If you own or manage a business that uses independent contractors, you need to know when you can or cannot treat a worker as an independent contractor. This article answers some of the common questions about worker classification. INTRODUCTION Misclassification of employees as independent contractors is now a common phrase uttered by state and federal […]
A Rendez-vous With The Federal Sentencing Guidelines
a. Overview of the Federal Sentencing Guidelines Sentencing issues are arguably the most important part of a federal criminal case. When clients learn they are under criminal investigation, the first questions are often: “Can I go to jail for this?” “If so, how long will I have to spend in jail?” It is for this […]
LIFTING THE VEIL ON THE BLACK MARKET PESO EXCHANGE — PART II: THE MECHANICS
The BMPE consists of two interrelated activities. One occurs in Colombia: the purchase of accumulated drug dollars in America. And the other occurs in the United States: the actual delivery of drug dollars to the money exchanger’s associate in the United States. 1. Purchase of Dollars in Colombia The BMPE process begins when the cartel […]
LIFTING THE VEIL ON THE BLACK MARKET PESO EXCHANGE — PART I
Picture this. The date is July 2, 1991. You walk into a cavernous room that is half the size of a football field. Inside that room are rectangular tables that extend from one side of the room to the other. Piled upon these tables are stacks of United States dollars. The stacks are as high as […]
PENALTY AND INTEREST ABATEMENT: A LIGHT AT THE END OF THE TUNNEL OR A DEEP, DARK ABYSS?
The Internal Revenue Code contains a labyrinth of overlapping penalties designed to encourage taxpayers to file on time and to pay on time. Some of the more common penalties include: (1) the failure to file penalty; (2) the failure to pay penalty; (3) the civil fraud penalty for filing a frivolous tax return or for […]
LIENS AND LEVIES AND GARNISHMENTS, OH MY!
If you owe the IRS but do not pay your tax liability in full, the IRS will send you a tax bill demanding payment in full. If you do not pay in full or make other payment arrangements, the IRS will pursue collection of the taxes through liens, levies, or garnishments. I. Tax liens A […]
RETRIAL OF DAUGERDAS AND FIELD IN TAX SHELTER SCHEME IN FULL SWING
The retrial of former Jenkens & Gilchrist partner Paul Daugerdas in an illegal tax shelter prosecution is underway in the southern district of New York. Mr. Daugerdas and former BDO Seidman Chief Denis Field are accused of marketing and giving legal cover for tax shelters that had no economic purpose except to avoid taxes. Field, […]