International Taxation

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 …
Owe More Than $ 50,000 to the IRS? You May Be Risking More Than Just a Good Night’s Sleep …
Listen Hold on to your horses. The IRS recently adopted new procedures required under a 2015 law designed to clamp down on taxpayers with “seriously delinquent tax debts.” On January 16, 2018, the IRS issued Notice 2018-1, which has all of the bite of the execution of “Order 66,” an order implanted into the clones by …
Do I Need To Report Bitcoin On My FBAR?
Listen Many lawyers are borderline technophobes. In 2014, Chief Justice John Roberts wrote that the Supreme Court still used vacuum tubes to distribute messages long after these systems became available in Washington-area yard sales. “Judges and court executives are understandably circumspect in introducing change to a court system that works well until they are satisfied that …