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My quick take? The IRS was so hungry for an FBAR criminal conviction that it agreed to a plea deal with no jail time, even when the underlying tax evasion charge normally carries a year incarceration. Great result for Defendant (and counsel); great result for the IRS as they got headlines during their push for the OffShore Voluntary Disclosure (OVDI).
All U.S. Taxpayers are required to report foreign income on their tax returns. So why does the IRS require an additional FBAR form to be filed? If you were going to fail to disclose on one form, you would fail to disclose on the FBAR form, right? What possible purpose does …
Tax Court Rules No Time Limit on Innocent Spouse Claim – This is a huge win. The Tax Court reversed a bad decision…a decision that should bother anyone …
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