A Good Lickin'
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
UK corporate offence of failure to prevent tax evasion
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
The Panama Papers & The Tempo of International Corruption Cases
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
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
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
IRS is interested in U.S. Taxpayer financial accounts everywhere in the world. If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more
Under FATCA, an Event of Default (EOD) will occur if an Entity fails to perform required material obligations with respect to the due diligence, verification, withholding, or reporting FATCA requirements, or if the IRS...more
Bajo FATCA, un Evento de Incumplimiento (“Event of Default o EOD”) ocurrirá si una Entidad no cumple con las obligaciones materiales requeridas con respecto a los requisitos de diligencia debida, verificación, retención o...more
There was an IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the...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
IRS holds information that is sourced from the FATCA reports submitted by Foreign Financial Institutions (FFI) (on Form 8966 - FATCA Report) and by Individual US Taxpayers that have reporting obligations via Form 8938...more
On September 28, 2018, the IRS closed the Offshore Voluntary Disclosure Program (2014 OVDP). The 2014 OVDP (and prior 2011 and 2009 programs) had the purpose of providing Taxpayers that WILLFULLY failed to report foreign...more
Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...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
The days of avoiding taxes through hiding money or assets in unreported offshore accounts are gone. Nonetheless, there are still taxpayers with undeclared offshore accounts, as well as the banks and bankers that are...more
El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more
On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since...more
Both the American Bar Association (ABA) and the American Institute of Certified Public Accountants (AICPA) have written letters (3/19/18 for the ABA and 5/30/18 for the AICPA) to the IRS to obtain further definition and...more
The jurors in the Paul Manafort case had questions regarding the complex Foreign Bank Account Reports (FBARs) regulations. This was evidenced by the jury’s questions to the judge addressing the responsibility to file an FBAR...more
On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more
El 5 de Julio del 2018, el Inspector General del Tesoro para la Administración Tributaria (TIGTA) emitió un informe: https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titulado: "A pesar de gastar casi...more
On July 5, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report https://www.treasury.gov/tigta/auditreports/2018reports/201830040fr.pdf titled: “Despite Spending Nearly $380 Million, the...more