Streamlined Testimonial
Dear Michael, Your excellent work on the streamlined procedure and related certification , and your explanations and discussions with me, were very much appreciated. I am glad to have had the benefit of your experience and competence in completing the process. With every good wish, R.C.
OVDP & Double Counting: Traps for the Unwary
Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the following: […]
Tax Planning on the Edge – Ride or Die in the International Tax Arena
The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to violate […]
Ms. Fournie Shows Fortitude In Fight Against IRS
A Message From Uncle Same To U.S. Taxpayers: No One Is Above the Law When It Comes to Filing Timely And Accurate Income Tax Returns
Just in time for the April 15, 2015 tax filing deadline, the IRS issued a press release entitled, “Justice Department Reminds Taxpayers that No One Is Above the Law or Below the Radar.” No further commentary is necessary. The title says it all. Click here to read the article.
IRS-CI Publishes 2014 Annual Business Report
IRS-CI recently published its 2014 Annual Business Report. It contains statistics regarding the conviction-rate for 2014 and is very insightful. Click here to view it.
OVDP And Double Counting: Oh The Agony! – Part II
This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period. This is a simple example, yet it illustrates some of the common mistakes that are associated with double […]
Roll On One
James Moore received a temporary reprieve from a federal judge in Seattle, but, at least metaphorically speaking, he is still strapped onto the mercy seat in classic John Coffey style, waiting to see what the onlooking guards will do next. No one really knows how Moore v. United States will turn out. What we do […]
Facing The Music
When I was a young, fresh-faced criminal defense attorney, there was an aged judge on one of the local benches. Courthouse rumor persisted that this gentleman, whose name I cannot recall, was a finalist to serve as Alf Landon’s running mate in 1936. The judge would occasionally say that his particular fiefdom should be called […]
A Message From Uncle Sam to Those With Foreign Assets: Don’t Forget Your U.S. Reporting Obligations
On April 10, 2015, the IRS issued a press release entitled, “IRS Reminds Those with Foreign Assets of U.S. Tax Obligations.” I’ve attached the relevant portions below: WASHINGTON — The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part […]