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Recent Posts
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Category Archives: STREAMLINED FILINGS
U.S. EXPATRIATES FEEL ABUSED BY FATCA AND OPPRESSIVE TAX REPORTING REGIME
I receive calls every day from U.S. Citizens living abroad who have recently learned that they are not compliant with U.S. tax filing and reporting obligations. They are angry, confused and frustrated. They’ve never heard of these requirements before getting … 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
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
NONWILFUL AFFIDAVITS UNDER THE STREAMLINED FILING COMPLIANCE PROCEDURES
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
DOJ PRESS RELEASE: THREE MORE SWISS BANKS SIGN NON-PROSECUTION AGREEMENTS – IMPLICATIONS FOR MISCREANTS NOT YET IN OVDP
The Department of Justice announced today that BNP Paribas (Suisse) SA (BNPP), KBL (Switzerland) Ltd. (KBL Switzerland) and Bank CIC have reached resolutions under the department’s Swiss Bank Settlement Program. These banks will collectively pay penalties totaling more than $81 … Continue reading
STATUTES OF LIMITATIONS WORK TWO WAYS
In my blog post of August 10, 2015 (Statutes of Limitation and Streamlined Filings or File Forward Strategies) I discussed the impact of various statutes of limitations (SOLs) on Streamlined Filing decisions. It is important to remember that SOLs are a … Continue reading