The IRS has stepped up its efforts to curb non-disclosure of offshore assets and underreported income by U.S. taxpayers. Tax compliance has risen to the top of the IRS agenda, and with widely publicized alerts from the IRS, claims of ignorance of the law aren’t likely to go very far.

Contrary to popular belief, not all foreign assets owned by U.S. taxpayers must be disclosed. This blog provides guidance to U.S. taxpayers who store gold and currency cash notes abroad in private vaults – a popular investment these days considering the uncertain global economy and the sharp declined in currency values.

Let’s begin with some basics. A U.S. person must file an FBAR if that person has Read More

This article was co-authored by Randall Brody, EA of Tax Samaritan. I wish to acknowledge his keen insight and invaluable contributions to this article.

Picture this. You receive a notice of determination from the IRS informing you that you owe more tax than you reported on your tax return. As is usually the case, the IRS issues a 30-day letter, advising you that you have 30 days to request Appeals consideration of the case.

But a new interim guidance issued by the IRS might make waiting for such a letter the equivalent of “waiting for Godot.” Why? This new guidance severely restricts the rights of certain taxpayers from seeking redress of their disputed tax determinations in Appeals, by Read More

In a recent IR published on January 28, 2015, the IRS said that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its “annual list of scams known as the ‘Dirty Dozen’ for the 2015 filing season.” The article is quoted below:

WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing season.

“The recent string of successful enforcement actions against offshore tax cheats and the financial organizations that help them shows that it’s a bad bet to hide money and income offshore,” said IRS Commissioner John Koskinen. “Taxpayers are best served by coming Read More

Are you looking for a fun way to kill a few minutes when you think the boss isn’t looking, and the company’s firewall restricts access to your favorite website? Google the phrase, “the defendant showed no remorse” and see how many hits you get. I witness this phenomenon firsthand almost every day. When the judge pronounces sentence, either after a trial verdict or as part of a plea bargain agreement, the defendants typically show no emotional response.

A large part of this apathy is “monkey see, monkey do.” That’s the demeanor that fictional and quasi-fictional defendants present on TV, so many of my clients assume they are supposed to behave the same way. Others are in shock after they hear an unfavorable verdict, while others are simply overwhelmed by the process and really have only a vague Read More

The U.S. Attorney’s Office for the Southern District of New York issued a press release on January 20, 2015 announcing the guilty plea of a CEO for hiding over $ 8.4 million in offshore Swiss bank accounts. George Landegger, the Chairman and CEO of an international pulp mill company, pled guilty to willfully failing to file FBARs for accounts that he maintained at a Swiss bank located in Zurich, Switzerland.

Landegger owned these accounts for nearly ten years, from the early 2000s up until 2010. During that time, his undeclared assets reached a high value of over $8.4 million.

What got Mr. Landegger into this “hot mess?” At the most primitive level, Mr. Landegger failed to report numerous Swiss bank accounts that he held for nearly ten years. But like Read More

Over the last two years, the number of U.S. expatriations has skyrocketed. For 2013 alone, the number of Americans renouncing their citizenship has increased to 221%. As shocking as this statistic might appear, according to those in the “know,” it is grossly understated. This has inspired many to call the trend, “Ellis Island in reverse.”

What has caused so many to resort to something as extreme as renouncing their U.S. citizenship? None other than the usual suspects, or what I like to refer to as the “dynamic duo” (for all you “Batman” fans): the United States’ system of worldwide taxation, on the one hand and FATCA, on the other. While I could go on endlessly about the harmful effects of global tax reporting and FATCA, the purpose of this blog is to discuss the steps that must be taken in order to expatriate. Read More

Those who responded to the altar call after one of Billy Sunday’s sermons (see video below) were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer.

Before he became a travelling evangelist, and possibly even before he became a Christian, depending on what source you believe, Mr. Sunday played eight seasons of Major League Baseball between 1883 and 1890. During that time, he roamed the outfield for the Chicago White Stockings, Pittsburgh Alleghenys and Philadelphia Phillies. Mr. Sunday left the game with a lifetime .248 batting average, which was pretty good for the pre-modern era. He was also a speedy player who finished in the top ten in stolen bases three times and led the league in outfield putouts in 1888. Read More

A Lowell chiropractor was recently sentenced in federal court in the District of Massachusetts for bribing an IRS agent.

Stephen Jacobs, age 56, was sentenced by U.S. District Court Judge William G. Young to nine months in prison and ordered to pay a fine of $ 10,000.

In October 2014, Mr. Jacobs pleaded guilty to bribery of a public official. According to the indictment, Mr. Jacobs met with an IRS auditor back in August of 2013 to answer questions pertaining to his 2011 federal income tax returns.

During the interview, the examiner asked Mr. Jacobs about two deductions that he had claimed for tax year 2011 – each in the amount of $ 5,000. Mr. Jacobs admitted to paying Read More

This is in response to all the comments received on my post from last week entitled: Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For The Worldwide Taxation of Nonresident U.S. Citizens?

Thank you everyone for the lively discourse. I have to admit that when I sought off writing this blog, I had no idea that it was going to generate as many comments as it did. I just recently learned that it made the WSJ Expat Facebook page (thanks for the “heads up” Walter).

While I recognize that this topic inspires deeply-held beliefs and passionate debate, I have to compliment everyone for keeping the level of discourse both courteous and Read More

Folks with Panamanian bank accounts may soon be getting some official-looking envelopes in the mail, as the Justice Department recently served John Doe subpoenas on FedEx, DHL, Western Union and a number of other shipping and wire transfer companies. These summonses require the targets to turn over any documents or material relating to their business with Panama-based Sovereign Management and Legal, Ltd.

With typical government bravado, Deputy AG David Hubbert warned that “the world is getting smaller for tax cheats, and we will work with our partners at the IRS to vigorously enforce the nation’s tax laws against those who seek to avoid paying their fair share.” Read More

Six years into the government’s latest crackdown on offshore tax evasion, federal prosecutors have yet to win a signature jury trial. Of the 38 persons indicted since 2008, 25 have yet to be tried, so the government has plenty of opportunities to bag the heretofore elusive white whale. Most of these 25 defendants are Swiss nationals, and after recent events, the thoughts of pending offshore tax evasion charges may not exactly be keeping these bankers up at night.

The Raoul Weil saga has been well-chronicled, both in this space and elsewhere, in part because it has a number of object lessons. Fist of all, Big Brother is watching. Mr. Weil was indicted back in 2008. He was living in Switzerland at the time, which will not extradite a person to face financial crimes charges in another jurisdiction. But, Mr. Weil decided to take Read More

When we last left our anthropomorphic friends (see video below), Rigby was in a serious coma due to an allergic reaction from the eggs in the Eggscelent omelet, and doctors were not optimistic about his chances. Meanwhile, Mordecai discovered a long-lost journal from a former park employee that may hold the key to winning the challenge and the coveted trucker’s hat.

More to the point, when we last left our anonymous CFO and the company’s intrepid legal team, they were preparing for an “eggshell audit” from a government investigator. A Kovel Agreement can encourage open dialogue between professionals by expanding the attorney-client privilege, and there are certain things that government auditors can and cannot do. But what exactly are they looking for when they arrive? And how can you be ready? Read More