The Curious Case Of The Accidental American Taxpayer
The following article was published on Law360 on September 26, 2018. I’m honored to be a contributor to this fine legal publication. Click here to read the article.
A Quick Primer on Form 5471 and Some Hidden Pitfalls to Avoid
Form 5471 is triggered in situations where a “U.S. Person” owns an interest in a “foreign” (non-U.S.) corporation. The specific reporting requirements for Form 5471 are found in Internal Revenue Code Sections 6038 and 6046. Broadly speaking, the purpose of Form 5471 is to identify “U.S. Persons” who: own at least 10% of a “non-U.S.” […]
OVDP Sunsetting on September 28 – New Procedures On The Horizon
On September 4, 2018, the Internal Revenue Service (IRS) reminded taxpayers that they have until September 28, 2018 to apply for the Offshore Voluntary Disclosure Program (OVDP). Back in March, the IRS announced that it would be discontinuing the program on September 28, 2018. This does not mean that the IRS is going to discontinue pursuing taxpayers […]
Blockchain and Trademark Law: So Perfect Together? (JOR)
The following article appeared in the November-December 2018 edition of, “The Journal of Robotics, Artificial Intelligence & Law.” I am honored to be a contributor to this fine publication. Click here.
Failing to File an FBAR Can Mean Big Fines and Big Penalties
There’s no denying the will of the government. In the U.S., what the government says effectively goes, and if you don’t like it – well, that’s too bad. And nowhere is this truer than it is in the case of willful FBAR penalties. Imposed as a way to enforce foreign account reporting for American citizens both domestic and […]
The Curious Tax Case of Accidental Americans
In general, the United States government is adept at primarily imposing its laws and policies on those who live in the country or are otherwise closely associated with the goings-on of the country. This is, of course, as it should be – despite the occasional propensity of the government to stick its nose where it […]
FATCA Back In The News (GTW)
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The Weighty Burden Of The Full FBAR Penalty (GTW)
This article was published in the September 6, 2018 edition of Global Tax Weekly. Enjoy.
FATCA Back in the News
That pestilent FATCA law is back in the news again. Back on July 9, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report (July TIGTA Report) highlighting the IRS’ shortcomings in enforcing FATCA. For those unfamiliar with FATCA, it stands for “Foreign Account Tax Compliance Act.” Sometimes referred to derisively by the nickname […]
Evidence 101 Masterclass – From Torts to Tony Soprano
This video is from a recent presentation that I did for Marino Legal. I’m honored to be a lecturer for this prominent CLE provider. For information on earning CLE credit for this course, please visit the Marino Legal website.