Monthly Archives: November 2016

SLIP-SHOD STREAMLINED NON-WILLFUL CERTICATIONS WILL CAUSE TROUBLE AND EXPENSE THAT WILL EXCEED THE COST SAVINGS FROM HIRING A LESS EXPERIENCED TAX ATTORNEY

Some who call me shop around after we speak seeking a less expensive tax attorney. My billing rate is at the lower range of what equally experienced AV-rated tax attorneys charge. I know how much time at a minimum it … Continue reading

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TAXPAYERS MUST BECOME COMPLIANT WITH U.S. OFFSHORE TAX FILING REQUIREMENTS AND FBAR REPORTING BY 2016 – TIME MAY BE RUNNING OUT ON NON-WILLFULNESS CLAIMS

For some time now, I’ve been receiving frequent calls from U.S. citizens or Green Card holders living outside of the U.S. and U.S. citizens, Green Card holders and residents living in the U.S. who have been out of compliance with … Continue reading

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18 USC 3287- THE STATUTE WITHOUT LIMITATIONS – IMPACT ON OVDP DECISIONS

Title 18 of the United States Code Section 3287 – Wartime Suspension of Limitations Act (WSLA), provides as follows: When the United States is at war or Congress has enacted a specific authorization for the use of the Armed Forces, … Continue reading

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