Tag Archives: Robert S. Steinberg

SLIP-SHOD STREAMLINED NON-WILLFUL CERTICATIONS WILL CAUSE TROUBLE AND EXPENSE THAT WILL EXCEED THE COST SAVINGS FROM HIRING A LESS EXPERIENCED TAX ATTORNEY

Posted on November 24, 2016 by steinbergtaxlaw

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

Posted on September 23, 2016 by steinbergtaxlaw

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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WAITING IS A DANGEROUS GAME FOR THOSE STILL NOT IN COMPLIANCE WITH FOREIGN REPORTING RULES

Posted on April 26, 2016 by steinbergtaxlaw

Over 55,000 taxpayers have come into compliance by entering the Offshore Voluntary Disclosure Program. An untold number of less culpable non-willful taxpayers have come into compliance under the Streamlined Filing Compliance Procedures.  Some with reasonable cause have used the delinquent … Continue reading →

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OFFSHORE NONCOMPLIANCE: THE NIGHTMARE THAT MORNING DOES NOT END

Posted on April 14, 2016 by steinbergtaxlaw

From every bad dream there is an awakening. Morning brings you back to sanguinity.For those with offshore activities who are out of compliance with U.S. tax law, however,  morning will not come unless and until they undertake some course of … Continue reading →

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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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THE CLOCK IS TICKING ON THE 27.5% OVDP OFFSHORE PENALTY (AS OPPOSED TO 50%) FOR THOSE WITH ACCOUNTS AT BANKS SOON TO BE ADDED TO THE IRS BAD BANKS LIST

Posted on May 30, 2015 by steinbergtaxlaw

The Department of Justice (DOJ) on May 29, 2015 announced that four more Swiss banks had entered into non-prosecution agreements (NPA), namely: Societe Generale Private Banking (Lugano-Svizzera) SA (effective 5/28/15) MediBank AG (effective 5/28/15) LBBW (Schweiz) AG (effective 5/28/15) Scobag … Continue reading →

Posted in 2014 OVDP, OFFSHORE BANK ACCOUNTS, OFFSHORE VOLUNTARY DISCLOSURE PROGRAM | 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.

Posted on May 1, 2015 by steinbergtaxlaw

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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OVDP: WHAT HAPPENS IF THE TAXPAYER CANNOT RAISE THE FULL REQUIRED PAYMENT UNDER FAQ 25?

Posted on April 28, 2015 by steinbergtaxlaw

FAQ 25 lists the OVDP submission requirements and insofar as payment goes, provides: Payment to the Department of Treasury in the total amount of tax, interest, offshore penalty, accuracy-related penalty, and, if applicable, the failure-to-file and failure-to-pay penalties, for the … Continue reading →

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STREAMLINED NON-WILLFUL CERTIFICATIONS: DON’T LIE, DON’T’ EXAGGERATE AND DON’T CHERRY-PICK YOUR FACTS

Posted on March 9, 2015 by steinbergtaxlaw

The Department of Justice Tax Division acting assistant attorney general, Caroline Ciraolo, speaking at the Federal Bar Association Tax Section annual tax conference (reported by Nathan J. Richman, Tax Analysts Tax Notes Today, March 9, 2015), stated: We are taking … Continue reading →

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MORE FROM IRS ON NON-WILLFULNESS CERTIFICATION UNDER STREAMLINED PROCESS

Posted on February 7, 2015 by steinbergtaxlaw

New IRS Form for Certification The IRS in January 2015 issued new Form 14653 (14654 for U.S. persons residing in the U.S.) which revises and replaces the required Certification by. U.S. Person Residing Outside of the Unites States for Streamlined … Continue reading →

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