Category Archives: Uncategorized

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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ROBERT S. STEINBERG RECEIVES TOP 1% AMERICA’S MOST HONORED PROFESSIONAL AWARD FOR 2016

Below is a copy of a press release regarding my being awarded the above honor. In my over forty years of tax practice I have endeavored to maintain my personal commitment to professionalism and have attempted to represent with compassion … Continue reading

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

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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STREAMIINED FILING COMPLIANCE PROCEDURES FREQUENTLY ASKED QUESTIONS ADDRESS ONE CONCERN AND CREATE ANOTHER

The IRS occasionally posts updates to its Frequently Asked Questions for the Streamlined Filing Compliance Procedures, both for taxpayers residing in and outside of the United States. The last update of the FAQs was made by IRS on July 18, … Continue reading

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THE DANGER OF RELYING ON MEMORY IN STREAMLINED NONWILLFUL CERTIFICATIONS

A Wall Street Journal article of July 27, 2016, “How Inaccurate Memories Can Be Good for You,” by Sue Shelenbarger, discusses a number of studies that found benefits to people from even inaccurate memories. More important that accuracy is that … Continue reading

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MORE ON INHERENT RISK IN STREAMLINED NON-WILLFUL CERTIFICATIONS

I have posted often about the risk of using the Streamlined Filing Compliance Procedures, specifically about the risk of making a statement under penalties of perjury of the reasons the taxpayer believes his or her conduct in failing to comply … Continue reading

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