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Do I qualify for an offer in compromise?

Tax debts can spiral out of control to the point where the taxpayer’s ability to pay is rather limited. If the IRS tried to collect 100% of every dollar owed from every delinquent taxpayer, there would be a revolt. If there’s one thing that the IRS is good at, it’s controlling the masses. The Offer in Compromise Program is the IRS’s opportunity to look gracious and kind by giving people a break.

Streamlined Offshore Disclosure Eligibility

When trying to determine if you are eligible for the IRS Streamlined Offshore Disclosure Program, the first thing to ask yourself is, “Do I have criminal exposure?” If the answer is yes, it’s likely in your best interest to avoid the Streamlined program altogether; instead, you would probably …

Passive Foreign Investment Craziness

There’s no easy way to say this – PFICs are incredibly confusing. Because of that, I’m going to apologize before we even get started. Bear with me and we’ll all make it through to the other side relatively unscathed. A PFIC (Passive Foreign Investment Company) is …

Expats and passport revocation

Tax compliance for expats is even more difficult for US taxpayers who reside in the states. Expats have to be in compliance with both the country they live in and the US…

FinCEN should focus on crime, not FBARs

With the rampant criticism you’ll find around here for the Financial Crimes Enforcement Network (FinCEN), FinCEN Form 114 (a.k.a. “the FBAR”), and my open mockery of particular sections of the Bank Secrecy Act of 1970, one may get the idea that there is little respect for proper government roles …

Expats and IRS tax collection statute limitations

If you owe the IRS money, it’s very easy to feel that the odds are stacked against you. The IRS is the most powerful collection agency in the world and Congress has repeatedly given the IRS new tools to collect what they feel they’re owed…

Expats and IRS disclosure issues

Being a US person and living overseas isn’t a crime (even though it may sometimes feel like it). Expatriates, more commonly known as expats, are US citizens residing overseas. That part at least is simple. How the US tax code treats these citizens is where everything devolves into chaos. It’s …

Can you be indicted for not filing a tax return?

We’re going to get to the answer right away: yes, it is a federal crime to willfully fail to file a tax return (See 26 USC 7203 below). Well, that was easy, wasn’t it? Not so fast. With the IRS, nothing is ever that easy. Here’s the reality of …