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Tag Archive for tax amnesty programs

Appeals Court Finally Affirms One Million Dollar FBAR Penalty

Ephraim Moss, Tax Attorney

In a rather swift and harsh judgment, the Ninth Circuit Court of Appeals affirmed a lower court’s decision in favor of the IRS, which assessed an approximately $1.2 million penalty against a taxpayer for failing to disclose her financial interests in an overseas account.

The decision, U.S. v. Bussell, is noteworthy for two reasons. First, it shows the magnitude of penalty that can be reached, even with respect to an individual and a single foreign account and tax year (in this case, the relevant tax year was 2006). Second, it shows the type of taxpayer arguments that courts will likely reject when reviewing an FBAR penalty case. Read more

Citizen Based Taxation—What You Need To Know

Expats are America’s global front-line ambassadors. Everyday, their actions and attitudes help shape others’ perceptions of the U.S. and Americans.

They are also the 21st century pioneers, forging opportunities and lives away from our shores and in the wider world.

However far from the U.S. they venture though, they remain in the strange situation of having to file taxes twice, in the country where they live, as well as to the U.S. This is because the U.S. operates a citizenship based taxation system.

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The IRS Tax Amnesty Programs – Fact Or Fiction

Despite the overall success of the IRS tax amnesty programs in recent years, many expats remain hesitant to enter the programs due to a number of misunderstandings surrounding their requirements and their outcomes. In this blog, we separate fact from fiction so that you can decide intelligently whether tax amnesty is right for you. Read more

IRS Crackdown And The Future Of Tax Amnesty Programs

Ephraim Moss

With the recent heavy focus on Congress and the Trump’s administration’s tax reform proposals, it can be easy to forget that the IRS continues to proactively crackdown on offshore tax evasion. Read more