Monthly Archives: December 2016

DISTRICT COURT CONTINUE TO REQUIRE ONLY A PREPONDERANCE OF THE EVIDENCE TO SUPPORT A FINDING OF WILLFULNESS IN FBAR PENALTY ENFORCEMENT CASES.

Posted on December 18, 2016 by taxpenaltylawyer

The U.S. District Court for the Central District of California in U.S. v. August Bohanec and Maria Bohanec Case No. 215-CV-4347 ddp (FFMx) (filed 12/8/16) https://www.pacermonitor.com/public/case/8438973/United_States_of_America_v_August_Bohanec_et_al handed the IRS victories on two important issues: 1. Held that the standard of … Continue reading →

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CURRENT LIST OF U.S. EXHANGE OF TAX INFORMATON AGREEMENTS AND AUTOMATIC EXCHANGE OF TAX INFORMTION AGREEMENTS IN FORCE

Posted on December 6, 2016 by taxpenaltylawyer

Under various income tax treaties and other agreements a foreign country may make a treaty request for information about income earned in the U.S. by one of its citizens or residents. Other agreements provide for the automatic exchange of tax … Continue reading →

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