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Big Win for Taxpayers in A Watershed “Willful” FBAR Penalty Case

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 proof […]

OVDP And Double Counting: Oh The Agony!

What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is exponentially […]

The Truth About ‘Luck’

This appeared in a blog post authored by Jason Zook. It is very profound. I couldn’t wait to share it with you. Why I don’t believe in luck For as long as I can remember, the saying, “you just got lucky” or “that person is so lucky” has always made me cringe. I’ve never believed […]

Nuts & Bolts of Storytelling For Public Speakers: How to Raise the Stakes

Learning how to raise the stakes in a story is hugely important. The problem that storytellers encounter more often then any other when telling their stories is failing to show the audience that there were high stakes. When you find yourself going “Whoa…!” during a story, or when you find yourself moving to the edge of your seat anxious to hear […]

Nuts & Bolts of Storytelling For Public Speakers: How to Tell An Unforgettable Story

SIGNIFICANT DETAILS As you may have heard before, it’s better to be specific than general most of the time. Like, “the bright pink tulip in the window” is better than “a flower.” It’s said that great criminals and sociopaths are especially good at including specific details in their alibis, because specific details read as “authoritative” […]

Lessons Learned From The Recent Conviction of Swiss Banking Giant Credit Suisse

When European financial giant Credit Suisse AG pleaded guilty to assisting U.S. taxpayers evade federal income tax, there was a great deal of swagger at the Justice Department. Former Attorney General Eric Holder, in classic Clint Eastwood style, boldly proclaimed that “no financial institution. . .is above the law,” and that any other bank which […]