Month: July 2012

The 4th Circuit takes a hard line on FBAR penalties: The painful lessons learned from IRS FBAR Court Rulings in the 4th Circuit’s US v Williams reversal…

Changes In Overseas Tax Law. Anthony Parent, tax resolution lawyer, warns taxpayers that extensive documentation will be required in 2013 if they invest or operate a business overseas, due to changes in overseas tax law. Wallingford, Conn.

– July 25, 2012 – Anthony Parent, founder of IRS …

The IRS FBAR form is a required informational return for any US taxpayer who owns or controls foreign financial accounts totaling $10,000 or more. FBARs must be filed with the IRS every June, regardless if an extension to file a 1040 was filed or not. The FBAR is not sent in with form 1040, but …

OVDI stands for the IRS Offshore Voluntary Disclosure Initiative. Sometimes, it is referred to as OVDP, with the P standing for “procedure.” However, both OVDI and OVDP are the same exact thing (UPDATE 3 – 2016: It is now referred to as to …

The Foreign Account Tax Compliance Act, also known as FATCA, is an initiative launched by President Obama with the goal of keeping Americans from hiding funds offshore. While the plan may be well – intentioned, the way it’s written is going to make life very difficult for offshore businesses and …

Last year, the IRS was found to be in compliance of its own IRS asset seizure regulations 56% of the time (which if my memory serves me correctly, if were were to assign a letter grade to such performance, the most appropriate letter would be an ‘F’).

But great news. According to the the …

The 5th Circuit has just recently upheld the tax court in Dalton v. Commissioner.  I see three essential lessons in play.
But first, you might be asking, what is a Collection Due Process Hearing?
A collection due process hearing is where a taxpayer gets to appeal a tax collection technique or …