International Taxation

Lessons Learned from Manafort Conviction that Every Taxpayer Should Know
Listen The conviction of former Trump campaign chairman Paul Manafort on eight counts of financial crimes marks the first trial victory of Special Counsel Robert Mueller’s probing investigation into President Trump’s associates. After four days of deliberating, the jury found Manafort guilty of five counts of filing false tax returns on tens of millions of …
FATCA, the IRS, and You: The Importance of Reporting
Listen If you have offshore bank accounts, the reality of FATCA should be less mystery and more common knowledge. Short for the Foreign Account Tax Compliance Act, FATCA is the legislation behind the government’s ability to find your funds anywhere in the world and, subsequently, bring down punitive actions against those not following the rules. Bottom line? …
Is U.S. Citizenship-Based Taxation On Its Way Out?
Listen The prayers of Americans living overseas may have finally been answered. A bill is in the works in the United States Congress to establish “Territorial Taxation for Individuals” (TTFI). If passed, the bill would change the current tax regime from one of “U.S. citizenship-based taxation” to “residence-based taxation.” This would go a long way …
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 …