Category Archives: TAX

DOJ SETTLES WILLFUL FBAR PENALTY WITH HOLOCAUST SURVIVOR AFTER COURT DENIES ITS MOTION FOR SUMMARY JUDGMENT

Posted on November 8, 2023 by taxpenaltylawyer

The IRS had assessed a willful FBAR penalty against Walter Schik (Schik) in the amount of approximately $8.8 million for failure to timely file FinCEN Form 114 for the year 2007.  When Schik did not pay the assessed amount the … Continue reading →

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HOW IRS COLLECTS A TAX DEBT

Posted on September 7, 2023 by taxpenaltylawyer

NOTE: THIS POST IS DIRECTED AT TAXPAYERS WHO ARE NOT TAX PROFESSIONS.  HENCE, CITATIONS TO INTERNAL REVENUE CODE SECTIONS, REGULATIONS AND COURT CASES ARE, WITH ONE EXCEPTION, NOT INCLUDED. The IRS is the worst creditor to have. If you owe … Continue reading →

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SOME COMMON MISCONCEPTIONS ABOUT THE STREAMLINED FILING COMPLIANCE PROCEDURES

Posted on September 29, 2017 by taxpenaltylawyer

I receive many inquiries about Streamlined Filings from U.S. citizens or Green Card holders living outside the U.S. as well as from recent immigrants to the U.S. or work visa holders living inside the U.S. In all of these cases, … Continue reading →

Posted in 2014 OVDP, AMENDED RETURNS, FBARS, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , , , | Leave a comment

IRS Committed to Stopping Offshore Tax Cheating; Remains on “Dirty Dozen” List of Tax Scams for 2017

Posted on February 16, 2017 by taxpenaltylawyer

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 →

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

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 taxpenaltylawyer

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

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

Posted on November 3, 2016 by taxpenaltylawyer

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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DEPARTMENT OF JUSTICE AND IRS CONTINUE TO FOCUS ON CATCHING OFFSHORE TAX CHEATS

Posted on August 25, 2016 by taxpenaltylawyer

The Department of Justice Tax Division on August 17 released a transcript of comments made by Principal Deputy Assistant Attorney General, Caroline D. Ciraolo, who had spoken at the Panama Bankers Association Anti-Money-Laundering Conference.in Panama City, Panama. Some take-aways from … Continue reading →

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OWE TAXES? NO PASSPORT! IRS MAY SCUTTLE TRAVEL PLANS OF THOSE WHO DON’T PAY UP

Posted on November 24, 2015 by taxpenaltylawyer

Congress has a sneaky habit of attaching tax bills to end-of-the-year highway funding legislation. HR22, the Surface Transportation Reauthorization and Reform Act of 2015,” has tucked into Title 52 a nasty little tax ditty that creates new Internal Revenue Code … Continue reading →

Posted in COMPLIANCE, PASSPORTS AND TAX DEBTS, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , | Leave a comment

DOJ PRESS RELEASE: THREE MORE SWISS BANKS SIGN NON-PROSECUTION AGREEMENTS – IMPLICATIONS FOR MISCREANTS NOT YET IN OVDP

Posted on November 22, 2015 by taxpenaltylawyer

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 →

Posted in 2014 OVDP, OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, STREAMLINED FILINGS, STREAMONED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , | Leave a comment

IF YOU DID THESE THINGS YOU BELONG IN THE OVDP

Posted on November 6, 2015 by taxpenaltylawyer

Laura Saunders in an October 23, 2015 Wall Street Journal article, enumerates some of the devices used by Swiss Banks to help clients evade their U.S. tax obligations. She lists the following exposed tactics of the banks: Using numbered or … Continue reading →

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