FBAR (Foreign Bank Account Report TD 90-22.1) Tax Audits
I have been speaking a lot lately to the Internal Revenue Service’s (IRS) tax amnesty hotline to obtain answers to the many practical questions that have arisen under the IRS Tax Amnesty a.k.a. tax...
View ArticleTax Amnesty Requests Result in 30 Questions to Offshore Bank Account Owners
When the Internal Revenue Service (IRS) released its FBAR tax amnesty FAQs it stated that there would be no standard list of questions asked of foreign bank account holders who made a voluntary...
View ArticleOffshore Account Information Still Wanted by the Internal Revenue Service to...
The past few months have been filled with contention from the Swiss government and UBS in response to the Internal Revenue Service’s (IRS) “John Doe Summons,” which seeks to have UBS turn over the...
View ArticleUBS FBAR Summons Case Settlement Reached
On Friday it was announced that UBS and the Internal Revenue Service had reached a settlement in the IRS lawsuit against UBS. The lawsuit sought to require UBS to turn over the names of 52,000 U.S...
View ArticleUBS Offshore Tax Evasion Case Moves Closer to Disclosure
On Wednesday, the UBS offshore tax evasion case moved one step closer to UBS disclosing the names of persons the IRS believes have committed tax fraud and/or failed to file TD F-90-22.1, Foreign Bank...
View ArticleFourth UBS FBAR Tax Fraud Defendant Pleads Guilty
A Los Angeles, California man pled guilty to one count of failing to file a Foreign Bank Account Form TDF 90.22-1 (FBAR) pursuant to the Bank Secrecy Act 31 USC 5314. This is the fourth person with a...
View ArticleDeportation for Tax Fraud and Other Tax Crimes
Filing a false tax return in violation of Internal Revenue Code (IRC) Section 7206 can result in deportation of a resident alien, i.e. a green card holder, according to the 9th Circuit Court of...
View ArticleFBARs and More FBARs
I just returned from an ABA meeting of tax lawyers in Washington, D.C. It seemed like all of the tax attorneys (or at least the tax litigation attorneys) could find nothing to talk about, but Foreign...
View ArticleTax Preparers Beware! 6th Circuit Court of Appeals Affirms Dismissal of Tax...
The 6th Circuit recently taught an expensive lesson to a Michigan couple about carefully following procedure when dealing with tax problems and subsequent loss of their $64,000 refund occurred because...
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Have You Received a Deficiency Notice or Another Letter Regarding Tax...
You filed your taxes like you were supposed to and you should be able to spend the rest of the year free from worries about taxes. But, then one day it appears. The envelope is fairly nondescript...
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Treasury Inspector General: IRS mishandled 24,000 Tax Lien Notices
No taxpayer wants to receive news of a tax deficiency, tax audit, or other bad news from the IRS; however, it may turn out that the only thing worse than receiving bad news from the IRS is not...
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Unpaid Tax Debts? The IRS May Be Able to Revoke or Deny Your Passport in 2016
One’s failure to understand the obligations and duties one holds under the U.S. Tax Code can always result in significant additional penalties and interest on any unsatisfied tax debt. Aside from...
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The Failure to File Taxes in a Timely Manner May Impact a Taxpayer’s...
The Internal Revenue Code and the Bankruptcy Code are each complex laws, but when they intersect things can get quite confusing, and seemingly inconsequential facts can have serious legal...
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The Failure to File Taxes in a Timely Manner May Impact a Taxpayer’s...
Bankruptcy Appellate Panel Finds in Favor of the Taxpayer in Late-Filed Taxes Discharge Question In the previous blog post we set forth the facts in a bankruptcy proceeding where the IRS argued that...
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What Should I Look for in a California Tax Lawyer?
When you need tax help, it only makes sense to look for in-depth experience in all of the tax laws relevant to you and your business. Federal and California state tax laws are constantly changing, and...
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The IRS Is Not Always Right: How to Fight Back
Dealing with an IRS mistake can be a frustrating experience, but it happens fairly often. There are many different types of error the IRS can make: Wrongful calculation of penalties and interest...
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How Can I Stop IRS Collection Actions?
The IRS is a fearsome creditor that can gain access to many of your assets to satisfy your tax debt. Unlike other creditors it doesn’t need to bring a lawsuit to go after you’re the bulk of your...
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How to Use the IRS Fast Track Settlement Program for Small Businesses
Fast Track Settlement (FTS) is an IRS program designed to resolve tax disputes within 60 days with the help of a trained mediator. Small businesses and self-employed taxpayers can used this program to...
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What To Do When You Receive an IRS Notice
Receiving a notice from the IRS is not something most people look forward to. You may be confused as to what the notice is saying, and afraid of the possible consequences, such as owing substantial...
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Which Court Should You Use For Your Tax Dispute
There are actually four different courts that can be used for tax litigation. The United States Tax Court is the most commonly used option, but other courts may have advantages in certain situations....
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