What A Thoughtful Gift
If you receive a $50 check in the mail from your Nana in the UK a few days before your birthday, it is fairly easy to deal with the income tax consequences of this transaction, especially if the check comes in one of those generic puppy-dog cards from the supermarket. That being said, most accountants […]
Knowing When To Say When: Tax Practitioners & The Rules Governing the Giving of Legal Advice
During its previous term, in a case that definitely took a back seat to the Affordable Care Act, same-sex-marriage, and the other high-profile disputes that the Supremes attempted to resolve, the High Court might have changed the way that doctors, dentists, accountants, lawyers, and other professionals have done business for decades. In North Carolina State […]
Overcoming The Pitfalls of Certifying Non-Willfulness When Applying To The Streamlined Compliance Program
Of the recent changes made to the streamlined procedures, none have received as much attention – or stirred up as much debate – as the new rule requiring certification of non-willfulness as a condition for gaining entry. This blog focuses on the requirement of the new streamlined procedures that the failure to report income from […]
Frequently Asked Questions Pertaining to the 5-percent Miscellaneous Offshore Penalty
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How is the Miscellaneous Offshore Penalty Calculated Under the Streamlined Domestic Procedures?
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The Streamlined Procedures: Traps for the Unwary
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Clearing Up the Confusion Between the events that trigger an increase in the offshore penalty from 27.5% to 50% with the events that disqualify a taxpayer from participating in OVDP altogether
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A Primer on DOJ’s Swiss Bank Program
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What Should I do if I receive a “Declaration of Consent” Form from My Swiss Bank?
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The Mechanics of How Information Gets Exchanged
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