Category Archives: AMENDED RETURNS

SOME COMMON MISCONCEPTIONS ABOUT THE STREAMLINED FILING COMPLIANCE PROCEDURES

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

NON-WILLFUL FBAR PENALTY: TAXPAYER FOUND BY DISTRICT COURT TO LACK REASONABLE CAUSE FOR HAVING FAILED TO FILE FBARS. COURT ALSO RULES AGAINST TAXPAYER ON DUE PROCESS AND EXCESSIVE FINE ARGUMENTS.

After James Moore had filed amended returns and delinquent FBARS, the IRS assessed against him maximum non-willful FBAR penalties of $10,000 for each of the years 2005 through 2008, for a total of $40,000.  Instead of waiting for the Treasury … Continue reading

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HOW NOT TO VOLUNTARILY DISCLOSE AN UNREPORTED OFFSHORE FINANCIAL ACCOUNT

A Wall Street Journal of March 14, 2015 by Laura Saunders reveals how Gregg Kaminsky and his tax advisors violated the cardinal rule of voluntary disclosure practice, “Don’t make things worse than they already are.” Kaminsky, now a 46 year-old … Continue reading

Posted in 2014 OVDP, AMENDED RETURNS, LESSONS FOR OFFSHORE TAX COMPLIANCE, ROBERT S STEINBERG, STREAMONED FILING COMPLIANCE PROCEDURES, WRONG WAY TO VOLUNTARILY DISCLOSE OFFHORE ACCOUNTS | Tagged , , , , | Leave a comment

ACCIDENTAL U.S. TAX RESIDENTS CAUGHT IN OFFSHORE DISCLOSURE WEB

One of the difficult aspects of U.S. tax law for foreign persons to understand is how they become accidental U.S. tax residents.  Even those here without a Green Card on non-immigration visas, can be required in any given year to … Continue reading

Posted in 2012 OVDP, AMENDED RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , | Leave a comment

MORE ON RETURNS OF SAME-SEX COUPLES

It is noteworthy that the IRS announced new rules for same-sex couples  (Rev. Rul. 2013-17) discussed in my post of 9/3/2013 (IRS Issues Rules for Same-Sex Couples) applies to original or amended tax returns filed on or after September 16, 2013.  This means … Continue reading

Posted in AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, JOINT RETURNS, RETURNS, TAX | Tagged , , , , , , | Leave a comment

IRS ISSUES RULES FOR SAME-SEX COUPLES

On August 29, 2013 the Department of the Treasury and IRS jointly announced issuance of tax filing guidance for same-sex couples in response to the U.S. Supreme Court decision in U.S. v. Windsor, 570 U.S. __, 133 S. Ct. 2675 … Continue reading

Posted in AMENDED RETURNS, MARRIED PERSONS, RETURNS, TAX | Tagged , , , , , , , , , | Leave a comment

OVDP OR NOTHING AT ALL

The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading

Posted in 2012 OVDP, AMENDED RETURNS, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | Leave a comment