Tag Archives: ROBERT S STIENBERG

IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

Posted on February 26, 2015 by steinbergtaxlaw

On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.”  On the Webinar panel were two IRS officials:  David W. Horton, Director, IRS International Individual Compliance; and John C. McDougal, … Continue reading →

Posted in 2014 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , | 8 Comments

EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

Posted on December 10, 2014 by steinbergtaxlaw

An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74), astutely summarizes the most likely charged tax … Continue reading →

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

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 →

Posted in TAX | Tagged , , , , , , , , , , , , , , , | 4 Comments

SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES

Posted on July 21, 2014 by steinbergtaxlaw

An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs, Penalties”), reveals what many professionals have … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 1 Comment

STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS

Posted on July 6, 2014 by steinbergtaxlaw

The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts.  We know that foreign banks are taking steps to minimize their risk of criminal prosecution … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , | 2 Comments

RESIDENCE OF PARTICIPANTS IN 2009 OVDP AND FOREIGN COUNTRIES IN WHICH DISCLOSED FINACIAL ACCOUNTS WERE LOCATED

Posted on February 21, 2014 by steinbergtaxlaw

On January 6, 2014 the U.S. Government Account Office (GAO) reported to Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, certain information about the participants in the 2009 IRS Offshore Voluntary Disclosure Program … Continue reading →

Posted in TAX | Tagged , , , , , , , , , , , , | Leave a comment

LUMP SUM ALIMONY ARREARAGES SATISFIED USING A QDRO

Posted on July 27, 2013 by steinbergtaxlaw

The following question was recently posted on the American Bar Association Tax Law and Practice Discussion Board: A taxpayer who we shall describe as the Former Husband (FH) agrees to settle alimony arrearages owed to his Former Wife (FW) by … Continue reading →

Posted in DIVORCE, QDRO, TAX, Uncategorized | Tagged , , , , | 4 Comments

OFFSHORE PROBES EXPAND BEYOND SWITZERLAND: NOMINEE ENTITY FAILS TO SHIELD TRUE ACCOUNT OWNER

Posted on May 5, 2013 by steinbergtaxlaw

Two recent guilty pleas in a California District Court, announced in April by the DOJ, should shake what complacency remains for those with unreported offshore accounts outside of Switzerland.  The IRS can find you even if your account is in … Continue reading →

Posted in 2012 OVDP, TAX, Uncategorized | Tagged , , , , , , , , , , , , , , | Leave a comment

FORMER HUSBAND COULD NOT ESCAPE OBLIGATION TO PAY FEDERAL INCOME TAX DEBT UNDER A STATE COURT FINAL JUDGMENT BECAUSE FORMER SPOUSE SUBSEQUENTLY WAS DENIED INNOCENT SPOUSE RELIEF BY IRS

Posted on September 3, 2012 by steinbergtaxlaw

In Settonni v. Settonni, the Ohio Court of Appeals for the Eighth District, Cayahogo County (Case No. 97784, Released July 5, 2012), upheld a lower court ruling that denied, without an evidentiary hearing, the former husband’s timely filed motion to set … Continue reading →

Posted in DIVORCE, INNOCENT SPOUSE, TAX, TAX INDEMNIFICATION CLAUSE | Tagged , , | Leave a comment

PRECISE LANGUAGE IN TAX INDEMNIFICATION CLAUSE COULD AVERT LATER DISPUTES – SPOUSE FOUND IN COMTEMPT OF COURT FOR VIOLATING TYPICAL CLAUSE WITH GENERAL LANGUAGE

Posted on March 12, 2012 by steinbergtaxlaw

In Brooks Lee v. Lee, 212 Ohio 373, Ohio Court of Appeals, 10th Appellate District (2012), the former husband appealed the decision of the trial court finding him in contempt on several grounds.  The case involved cross motions for contempt … Continue reading →

Posted in DIVORCE, INNOCENT SPOUSE, RETURNS, TAX, TAX INDEMNIFICATION CLAUSE | Tagged , | Leave a comment