Search Results for: will o the wisp willfulness

WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE

Posted on September 1, 2014 by steinbergtaxlaw

“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia).  Most clients with unreported offshore accounts who … 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

Posted on November 17, 2016 by steinbergtaxlaw

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 →

Posted in 2014 OVDP, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , | Leave a comment

CAUTIONARY TALE FOR POTENTIAL STREAMLINED FILERS AND ADVISORS

Posted on April 23, 2020 by steinbergtaxlaw

The Streamlined Filing Compliance Procedures (Streamlined process or filing)represent a very attractive process by which certain non-compliant taxpayers can come into compliance without penalty (for those living outside of the U.S. who meet a non-residency test) or with a 5 … Continue reading →

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OFFSHORE NONCOMPLIANCE: THE NIGHTMARE THAT MORNING DOES NOT END

Posted on April 14, 2016 by steinbergtaxlaw

From every bad dream there is an awakening. Morning brings you back to sanguinity.For those with offshore activities who are out of compliance with U.S. tax law, however,  morning will not come unless and until they undertake some course of … Continue reading →

Posted in OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , , , , , , | Leave a comment

NONWILFUL AFFIDAVITS UNDER THE STREAMLINED FILING COMPLIANCE PROCEDURES

Posted on January 28, 2016 by steinbergtaxlaw

Normally, the tax-rules that taxpayers must follow are contained in the Internal Revenue, Code, Treasury Regulations promulgated by the IRS, Revenue Rulings issued by the IRS and court cases. For taxpayers seeking to enter either the IRS’ formal criminal amnesty … Continue reading →

Posted in STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , , | Leave a comment

SOME CLARIFICATION FROM IRS ON THE STREAMLINED FILING COMPLIANCE PROCEDURES.AND DEINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSIONS.

Posted on November 9, 2014 by steinbergtaxlaw

The IRS has updated its Streamlined Filing Compliance Procedures and Delinquent International Information Return pages (October 9, 2014) and issued Frequently Asked Questions with regard to each. The FAQs for U.S. Taxpayers residing in the U.S. clarify that: The 5% … Continue reading →

Posted in 214 OVDP, COMPLIANCE, FBARS, OFFSHORE BANK ACCOUNTS, TAX | Tagged , , , , , , , , | 1 Comment