Category Archives: UNFILED RETURNS

SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED COMPLIANCE PROCEDURES FOR U.S. EXPATS

Posted on July 15, 2014 by taxpenaltylawyer

“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives for resolving offshore noncompliance exposure of U.S. citizens and permanent residents who … Continue reading →

Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

IRS FIRST TIME ABATE POLICY PROVIDES PENALTY RELIEF IN CERTAIN SITUATIONS

Posted on June 1, 2013 by taxpenaltylawyer

The IRS today clarified its policy with regard to abatement of certain penalties for first time offenders.  The policy was modified to clarify that relief applies only where the taxpayer is current with all tax filings and tax payments. See IRM … Continue reading →

Posted in COMPLIANCE, DELINQUENT RETURN, EMPLOYMENT TAXES, IRS COLLECTIONS, POLICY, RETURNS, TAX, TRUST FUND PENALTY, UNFILED RETURNS | Tagged , , , , , , , | 6 Comments

“LISTEN, DO YOU WANT TO KNOW A SECRET?”

Posted on April 13, 2013 by taxpenaltylawyer

The Beatles sang in the 1960s of sharing secrets and promising not to tell.  In an age of  prying governments with big eyes and long arms, malicious internet hackers, of snoopers panting to expose, and whistle-blowers coveting gain, what reality remains in these naïve expectations?  The … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, FBARS, TAX, TAX CRIMES, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , | Leave a comment

IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

Posted on March 23, 2013 by taxpenaltylawyer

Two high level IRS Criminal Investigation (CI) officials participated an American Bar Association, Tax Section, Webinar, “Criminal Tax Enforcement Hot Topics: The IRS Perspective,” (March 20, 2013).  Edward “Ted” Cronin is the Division Counsel/ Associates Chief Counsel (Criminal Tax) … Continue reading →

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

COMPELLED TO SELF-INCRIMINATE: EROSION OF THE FIFTH AMENDMENT’S PROTECTION FOR PERSONAL FOREIGN BANKING RECORDS REQUIRED TO BE KEPT UNDER BANK SECRECY ACT REGULATIONS

Posted on September 30, 2012 by taxpenaltylawyer

Many legal scholars on both sides of the Obamacare debate have voiced concern about Chief Justice Roberts’ opinion in the Supreme Court’s decision on the Patient Protection and Affordable Care Act, specifically upholding the Act based on Congress’ power to … Continue reading →

Posted in FBARS, TAX, TAX CRIMES, Uncategorized, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , , | Leave a comment

STILL OUT IN THE COLD? IRS LEAVES OPEN DOOR FOR VOLUNTARY DISCLOSURE – 2012 OVDP

Posted on August 6, 2012 by taxpenaltylawyer

As Global Warming is said to be melting the arctic glaciers, safe havens for offshore tax scofflaws are dwindling from increasingly strident global economic pressure applied to tax haven jurisdictions. Now, tax haven countries wishing to participate in the global … Continue reading →

Posted in 2012 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

THERE ARE NO MAGIC TRICKS FOR RESOLVING TAX DEBTS OF THE NON-FILER: CAUTION NOT SPEED SHOULD BE THE WATCH WORD.

Posted on April 17, 2012 by taxpenaltylawyer

Booker T. Washington said, “Nothing ever comes to one that is worth having, except as a result of hard work.”  There is no easy solution to resolving tax debts.  Anyone who claims to be able to eliminate tax debts quickly … Continue reading →

Posted in DELINQUENT RETURN, INNOCENT SPOUSE, IRS COLLECTIONS, RETURNS, TAX, TAX CRIMES, UNFILED RETURNS | Tagged , , , , | Leave a comment