IRS to End Offshore Voluntary Disclosure Program
The IRS announced recently that it is ending the OVDP program which has been in existence since 2009. Here are more details from the announcement. …
The IRS announced recently that it is ending the OVDP program which has been in existence since 2009. Here are more details from the announcement. …
Dewees v. United States, 16-cv-01579 (D.C. 2017) is a difficult case. The IRS appears to have been unusually tough on this taxpayer. Dewees is a U.S. citizen …
IRC § 6038D, enacted on Mar. 18, 2010, and effective for taxable years beginning after the date of enactment, imposes reporting requirements with respect to …
While a U.S. corporation is subject to tax on its earnings and then its shareholders on their dividends, the U.S. has no taxing jurisdiction on …
FATCA, treaty exchanges, and deferred prosecution agreements are some of the ways that IRS can be tipped off to your foreign accounts. Foreign Account Tax …
FIRPTA witholding rules may apply to a disposition of a U.S. real property interest by a foreign person. Such transactions are subject to the Foreign …
A question that’s commonly asked by prospective clients in a streamlined compliance filing is: “will I get audited?” This article will hopefully shed some light. …
How U.S. Life Insurance Policies are Taxed A whole life insurance policy is part investment and part life insurance. Such policies have two basic financial …
How much does a streamlined case cost? Foreign accounts cases are unique and present different challenges. We often get quote requests by email. Hopefully this …
Domestic Voluntary Disclosure The IRS issued a memorandum on November 29, 2018 that updates the process for domestic and offshore voluntary disclosures after the 2014 offshore voluntary disclosure program …