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Author Archives: steinbergtaxlaw
RIVERBOAT GAMBLERS, THE OVDP, AND UNREPORTED OFFSHORE ACCOUNTS
Prospective clients often ask me, “What is the likelihood of my unreported offshore bank account being discovered?” My answer is always: “Very likely if you are caught.” I don’t mean to be cute by answering thus. What I am … Continue reading
COMPROMISE AND TAX REFORM – THE LOST ART
Departing from offshore tax issues, this post offers a philosophical discussion of the lost art of compromise and how ideology is hampering the ability of congress to govern. Even within the GOP, now in control of both houses, ideological differences … Continue reading
IRS Committed to Stopping Offshore Tax Cheating; Remains on “Dirty Dozen” List of Tax Scams for 2017
IRS Newswire Issue No. IR-2017-35, February 16, 2017 is reproduced below in its entirety. WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its 2017 list of tax … Continue reading
2016 FILING STRATEGY FOR OFFSHORE NONCOMPLIANT TAXPAYERS
I have previously posted on the need for those who are still out of compliance with U.S. tax law to become compliant with their 2016 tax and FBAR filings. “See post of 11/17/16 Taxpayers Must Become Compliant with U.S. Offshore … Continue reading
CURRENT LIST OF U.S. EXHANGE OF TAX INFORMATON AGREEMENTS AND AUTOMATIC EXCHANGE OF TAX INFORMTION AGREEMENTS IN FORCE
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
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
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
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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