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14 Oct 2012, 10:47 am by sandylaw
Ultimately FATCA may result in disclosure of the account to the IRS and the funds may still be blocked. [read post]
7 Oct 2012, 10:23 am by sandylaw
The question often arises in the context of value of assets other than financial assets being added to the penalty base by the IRS. [read post]
1 Oct 2012, 5:32 am by admin
High risk factors include material economic activity in the United States, ongoing IRS investigation or audit, and previously assessed FBAR penalties. [read post]
30 Sep 2012, 10:36 am by sandylaw
This “exit” tax is doe not relieve U.S. taxpayers of FBAR or income tax compliance but is in addition to those compliance obligations. [read post]
28 Sep 2012, 9:54 am by Jay R. Nanavati
” For more information on the government’s offshore enforcement efforts, FBAR penalties, and the IRS’s Offshore Voluntary Disclosure Program (OVDP), please contact Jim Mastracchio at (202) 861-1650 (Jmastracchio@bakerlaw.com) or Jay Nanavati, (202) 861-1747 (jnanavati@bakerlaw.com), Baker Hostetler LLP, 1050 Connecticut Ave., Washington, DC 20036 (www.bakerlaw.com). [read post]
24 Sep 2012, 2:29 pm by admin
Most importantly opting out of the 27.5% FBAR equivalent penalty. [read post]
23 Sep 2012, 9:46 am by sandylaw
For all these reasons and more, it is important for taxpayers to consider the coming forward now, before their information is obtained by the DOJ or IRS and they are then prevented from entering the Offshore Voluntary Disclosure Program (OVDP) because they are no longer eligible. [read post]
13 Sep 2012, 3:41 am by LindaMBeale
 And did he report his offshore accounts and income as he was supposed to, back in the days before Birkenfeld opened the crack in Swiss banking secrecy, or did he end up participating in the IRS amnesty program in order to avoid criminal prosecution for his failure to file FBARs? [read post]
12 Sep 2012, 2:59 pm by Pamela
There is a new compliance offer by the IRS that gives those who qualify a chance to avoid all penalties for not filing the FBAR and not filing U.S. income tax returns. [read post]
10 Sep 2012, 5:00 am
Once again tax attorneys will be working full time to guide their clients through another thicket of IRS rules which seem only to reinforce the notion that the IRS is not serious about providing FBAR relief to those taxpayers who legitimately lost their way. [read post]
9 Sep 2012, 10:00 am by sandylaw
The IRS has published examples of when an “opt out” may be advantageous and when not (see OVDP FAQ 51.1). [read post]
6 Sep 2012, 4:17 am by admin
Americans, living in a foreign country, who have not filed their federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs) have been given amnesty by the Internal Revenue Service (IRS). [read post]
5 Sep 2012, 8:14 am by admin
Is the IRS bound by any hard and fast rules? [read post]
28 Aug 2012, 8:52 am by Jay R. Nanavati
For more information on the government’s offshore enforcement efforts, FBAR penalties, and the IRS’s Offshore Voluntary Disclosure Program (OVDP), please contact Jim Mastracchio at (202) 861-1650 (Jmastracchio@bakerlaw.com) or Jay Nanavati, (202) 861-1747 (jnanavati@bakerlaw.com), Baker Hostetler LLP, 1050 Connecticut Ave., Washington, DC 20036 (www.bakerlaw.com). [read post]
26 Aug 2012, 11:14 am by Fred Abrams
 The July 20th decsion discusses the IRS’s right to collect civil penalties against U.S. taxpayers who fail to file a TDF 90-22.1, Report of Foreign Bank and Financial Accounts (“FBAR form”). [read post]
25 Aug 2012, 3:44 pm by sandylaw
What is important is that the taxpayer failed to file an information return(s) and the result was the assertion by the IRS of substantial civil penalties. [read post]
24 Aug 2012, 12:32 pm by Darrin Mish
  Milwaukee Neurosurgeon Convicted of Tax Evasion is a post from: IRS Tax Problem Solver Blog - IRS Help [read post]
22 Aug 2012, 6:19 am by Joe Kristan
  Credit Suisse / Wegelin Client Pleads Guilty to FBAR Violation in SDNY (Jack Townsend) Dear Readers: Is my opinion of Commissioner Shulman too nuanced and subtle? [read post]