IRS Wins Default Judgment in $18M FBAR Penalty Case
Recently, a California U.S. District Court entered default judgment in favor of the Government in an FBAR penalty suit in the case of United States …
How to Read Tax Treaties
We write this article because we frequently have clients come to us after having read another blog or after their own casual reading of an …
Reporting Beneficial Interest in a Foreign Trust & Form 3520
According to the IRS, foreign trusts are a major compliance issue: Citizens and residents of the United States are taxed on their worldwide income. To …
IRS Sues Taxpayer to Collect on $5M FBAR Penalty
Earlier this month, in United States v. Arvind Ahuja (E.D. Wisc. Dkt. No. 18-cv-01934), the IRS sued a prominent neurosurgeon to reduce to judgment an …
IRS Updates Procedures for Voluntary Disclosures
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 …
IRS Includes FATCA in 5 New Compliance Campaigns
Each year the IRS rolls out campaigns to identify the the top compliance issues for the year. For each of these campaigns, the IRS will …
IRS Evaluates Crytocurrency Taxable Events
At a recent conference, the IRS opened up about its cryptocurrency compliance efforts. To combat tax evasion from those engaged in cryto trading, the IRS …
Court Finds Representative of Estate Liable for Deceased’s FBAR Penalties
The Court in United States v. Schoenfeld (M.D. Fla. 3:16-cv-1248-J-34PDB) finds that a deceased taxpayer’s FBAR civil penalty liabilities are collectible from his estate’s beneficiary. Facts Steven …
Tax Court Denies Government Summary Judgement in Foreign Income Case
In Zuhovitzky v. CIR, T.C. Memo 2015-158, the government filed a motion for partial summary judgment on the issue wither the petitioner is subject to …
Late Filed Foreign Earned Income Exclusion
Can the foreign earned income exclusion be elected on a late-filed return? Redfield v. Comm’r, T.C. Memo 2017-71 (T.C. April 26, 2017) answers this question. …