Some events are so seminal that they need no explanation. When someone says “Holocaust” or “9/11” or “Hindenburg,” no further explanation is needed. Some sports stars share similar fame. There is only one Michael, one LeBron, and one Wilt. While he admittedly does not rise to that level – some scouts shake their heads and say his left-handed layup needs work – James Moore’s rather commonplace name may someday reach that upper echelon.
A few months ago, I posted on the curious case of Moore v. United States. That article has an exhaustive discussion of the facts and also of FBAR. In a nutshell, Mr. Moore did not file an FBAR for 2003-2008; he filed late in 2009. The IRS conducted an investigation and sent Mr. Moore a memo in 2011 which curtly informed him that, after due Read More
Ancient Greek thinker Heraclitus is famous, at least in some circles, for his rather perplexing observation that “the only constant in the universe is change.” Murphy’s Law, a much more familiar axiom, states that “if anything can go wrong, it will.” If these two phrases are combined into some sort of latter-day Frankenstein’s monster of philosophy, you may get something like “change never happens as quickly as you want it to happen.”
Dodd-Frank, the massive 2010 financial reform law which Republicans and their banker allies have taken a blood oath to dismantle while Democrats and their consumer advocate allies have been known to worship with wave offerings, is a good example. Five years after its passage, the law is still only about 50 percent implemented. That’s good news for some people, and bad news for others. Read More
Wighead English jurist William Gladstone, the author of this famous quote, was obviously not a criminal defense lawyer. In many, if not most, cases, delay is a fundamental element of a successful defense, or even the lynchpin of the entire schmear. Over time, memories fade, evidence is lost (or at least becomes more difficult to find and use in court), witnesses relocate, and prosecutors lose interest in the case. All of these developments weigh in favor of criminal defendants.
To paraphrase Gordon Gekko: Delay is good. Delay is right; delay works. So, there were champagne corks popping all along Wall Street and into the uttermost parts of the earth when the IRS announced that it would delay certain FATCA bank withholding requirements until 2019. However, it remains to be seen whether the delay is a legitimate reprieve or Read More
Governments will try to get away with almost anything during wartime. In the Civil War, President Abraham Lincoln suspended the writ of habeas corpus so federal authorities could lock up suspected Confederate sympathizers and throw away the keys. This action was more than mere ink on paper; it was very vigorously enforced, especially in Maryland and other Border States. He also signed the Revenue Act of 1861, which put an income tax into effect. The government gave up in 1862, partially due to Constitutional concerns regarding the Apportionment Clause (all taxes must be apportioned between the states), but mostly because the Revenue Act simply didn’t raise much money.
Congress took care of that Constitutional technicality with the 16th Amendment in 1913. But it wasn’t until 1943 (yet another war) that the money started rolling in. (See Video Read More
“Passion is absolutely necessary to achieve any kind of long-lasting success.” In a minute, I will share with you who that quote belongs to but for this moment remember that passionate people have very strong beliefs. As I was arranging speakers for the Internet Tax Summit, the passion these tax experts have in protecting taxpayers and businesses was prevalent. You know when you encounter people in life with purpose and passion for what they do; you know they get things done. You can expect to encounter tax professionals who get things done at TaxConnections Internet Tax Summit. You are invited to meet and interact with Tax Experts in this historical event where individual taxpayers and business leaders meet tax experts during an online event. It is free so all you need to do is register and we will send you a link to access the Internet Tax Summit. Read More
Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist:
(1) At the time the taxpayer initiated their disclosure, one or more of the following applies:
a. A foreign financial institution at which the taxpayer had an account had been publicly identified as being under investigation, the recipient of a John Doe Summons or is cooperating with a government investigation, including the execution of a deferred prosecution agreement or non-prosecution agreement; or Read More
What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and anything else, that happened to be there at the time? Would they still be lounging in the Garden of Eden today, munching on pomegranates instead of apples and perusing through YouTube videos on their iPads?
What if a small team of British commandos had been unable to disable Nazi Germany’s deuterium oxide factory in Vermork in 1943, after several prior attempts had failed? Would Hitler have gained the final component he needed for an atomic bomb, and attached these weapons to the V-2 rockets falling from the sky onto London?
What if that Star Destroyer captain had blown R2-D2’s escape pod to smithereens in the Read More
Watching tax professionals reputations grow with higher visibility and authority in tax services is very exciting. Allow me to share the stories of tax professionals who are utilizing new marketing technology only available on www.taxconnections.com.
We focus on powerful native advertising strategies developed with TaxConnections proprietary software. For those of you who are unfamiliar with native advertising, it is a way to market your tax services without people realizing it is an ad about your tax services. We spent years developing this technology and we are delighted to see our members gaining new clients and authority for their tax expertise every day. Allow me to introduce some of our members and how they are accelerating their tax reputations. Read More
Our members blogs are read by visitors from 210 countries and territories around the world. We are amazed as we watch our members gain better visibility for their tax expertise and more authority in the marketplace. TaxConnections Bloggers have a unique style that resonates with our readers. We love the way our Tax Bloggers make the stories relatable to our readers. When you are marketing for new clients the secret is to make it less technical and more relatable. This week I want to give you all examples of our Tax Bloggers who had some of the most read blog posts over the past year: Michael DeBlis, John Dundon, Barry Fowler, Jeffrey Kahn, Manasa Nadig, Peter Scalise, John Stancil, Hugo van Zyl and so many more.
If you are interested in enjoying a wider distribution of your tax blogs and reputation to our hundreds of thousands of readers, please join us today!
Last weekend, media reports cast an unflattering light on HSBC’s continued defiance to “straighten up and fly right” when it comes to assisting its foreign clients hide their accounts from taxing authorities in their home countries. The list of clients includes some you would least expect: global politicians, rock stars, arms dealers, and potential terrorists. Not surprisingly, this did not sit too well with the IRS.
According to a report from the International Consortium of Investigative Journalists, HSBC’s Swiss private banking division was complicit in assisting its foreign clients to “dodge” tax authorities in their home countries. Specifically, they were all too willing to gave them tips on how to evade paying European Union taxes on their bank accounts. Read More
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
The battleground in the government’s ongoing war against financial criminals shifted to a Brooklyn courthouse last month, as another UBS defendant was sentenced after he pleaded guilty to concealing a foreign bank account. Prosecutors alleged that 73-year-old Gabriel Gabella, an Italian citizen, failed to file a Report of Foreign Bank and Financial Accounts (FBAR) to disclose his ownership of a Swiss bank account held at Union Bank of Switzerland in tax years 2006 and 2007.
Mr. Gabella faced a maximum 60 months in prison, and a guideline range of 24 to 30 months. However, U.S. District Judge Jack Weinstein sentenced him to three years’ probation and a $50,000 fine. In addition, Mr. Gabella paid a civil penalty of $3.1 million, which was about half the value of his account in 2007, and $239,000 in back taxes. Read More