Tax Chat

The Power to Tax
Listen The Taxing and Spending Clause (which contains provisions known as the General Welfare Clause) and the Uniformity Clause, Article I, Section 8, Clause 1 of the United States Constitution, grants the federal government of the United States its power of taxation. While authorizing Congress to levy taxes, this clause permits the levying of taxes …
Big Win for Taxpayers in A Watershed “Willful” FBAR Penalty Case
Listen I’m a little slow in getting around to this one, but back on September 20, 2017, the Eastern District of Pennsylvania released a taxpayer-friendly opinion regarding the “willfulness” standard in FBAR penalty cases. In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the district court held that the government had not met its burden of …
Waving Sayonara to OVDP
Listen On March 13, 2018, the Internal Revenue Service revealed that it will begin to wind down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program …