US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
THE WAY WE WERE
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more
What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more
U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more
On November 29, 2018, the Internal Revenue Service (the "IRS") published a memorandum (the "Memorandum") dated November 20, 2018, outlining the new process for all voluntary disclosures, both domestic and offshore (the "New...more
On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more