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IRS COMMENTS ON NEW STREAMLINED FILING PROCEDURES FOR NON-WILLFUL OFFSHORE...

 Amy S. Elliott’s article, IRS Answers Questions on Updated OVDP and Streamlined Filing, 2014 TNT 120-9 (6/23/14) summarizes selected comments of IRS officials at NYU’s recent Tax Controversy Forum....

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STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED...

The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts.  We know that foreign banks are taking steps to...

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IRS CRIMINAL INVESTIGATION DIVISION OFFICIALS PARTICIPATING IN ABA TAX...

On July 8, 21014 Edward Cronin, Associate Chief Counsel (Criminal Tax) and Don Fort, CID Director of Field Operations participated in an ABA Tax Section Webinar, “Current IRS Criminal Investigation...

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SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED COMPLIANCE PROCEDURES FOR...

“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives...

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THE TAX LAW IS COMPLEX; OFFSHORE COMPLIANCE DECISIONS ARE DIFFICULT AND...

John J. Scroggin published an interesting and entertaining survey of tax complexity in the Wealth Strategies Journal (Tax Complexity, History, and Humor, July 8, 2014). The article begins with a quote...

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SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP –...

An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs,...

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THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS

Many believe that you can bifurcate the Streamlined Process between the criminal aspect and civil aspect.  That once you have a non-willful opinion from the criminal tax lawyer, the process becomes...

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EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November...

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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS

Today the IRS released IR-2015-9, “Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season” which provides verbatim: WASHINGTON — The Internal Revenue...

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IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.”  On the Webinar panel were two IRS officials:  David W. Horton,...

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