Category Archives: Uncategorized

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

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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

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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

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DISTRICT COURT CONTINUE TO REQUIRE ONLY A PREPONDERANCE OF THE EVIDENCE TO SUPPORT A FINDING OF WILLFULNESS IN FBAR PENALTY ENFORCEMENT CASES.

The U.S. District Court for the Central District of California in U.S. v. August Bohanec and Maria Bohanec Case No. 215-CV-4347 ddp (FFMx) (filed 12/8/16) https://www.pacermonitor.com/public/case/8438973/United_States_of_America_v_August_Bohanec_et_al handed the IRS victories on two important issues: 1. Held that the standard of … Continue reading

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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

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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

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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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