Tag Archives: NONWILLFULNESS

2016 FILING STRATEGY FOR OFFSHORE NONCOMPLIANT TAXPAYERS

Posted on February 2, 2017 by steinbergtaxlaw

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 →

Posted in STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , , , | Leave a comment

FOR WHOM THE BELL TOLLS ON STREAMLINED FILINGS

Posted on March 12, 2016 by steinbergtaxlaw

A Tax Analysts Tax Notes article (Richman, Nathan J., “International Tax Enforcement Efforts Include Civil Tools”) quoted Acting Assistant Attorney General of the Department of Justice Tax Division, Caroline Ciraolo who was speaking at the March 4th Federal Bar Association … Continue reading →

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BLOOMBERG BNA SAMPLES ATTORNEY VIEWS ON STREAMLINED PROCESS

Posted on September 20, 2014 by steinbergtaxlaw

Alison Bennett of Bloomberg BNA’s article “Questions surround Standard of Willful Path Conduct under Streamlined Version of OVDP” (9/17/14), summarizes some of her interviews with tax lawyers around the country concerning the Streamlined Filing Compliance Procedures announced by IRS on … Continue reading →

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WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE

Posted on September 1, 2014 by steinbergtaxlaw

“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia).  Most clients with unreported offshore accounts who … Continue reading →

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