In U.S. vs. Richard M Rund, the U.S. District Court (ED of Virginia) granted the government’s Motion for Summary Judgment finding that the taxpayer had not demonstrated any genuine remaining dispute as to whether his failure to report foreign financial accounts was willful (Case No.1:23-cv-00549, August 6, 2024) Rund had […]
The Tax Wars Blog
FALSE ASSUMPTIONS ABOUT TAXES ARE DANGEROUS
ASSUMPTIONS IN LIFE We live our lives amidst a world of assumptions, the things we take for granted, not because they have been proved, but, because we simply believe them to be true. Sometimes we later find that we have made a false assumption like having once naively believed all […]
STREAMLINED FILING VERSES REGULAR FILING WITH REASONABLE CAUSE STATEMENT
“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to both fling delinquent returns using the Streamlined Filing Compliance Procedures or through normal filing channels with a Reasonable Cause Statement attached. . Calls I’ve received from both accountants and perspective […]
CAUTIONARY TALE FOR POTENTIAL STREAMLINED FILERS AND ADVISORS
The Streamlined Filing Compliance Procedures (Streamlined process or filing)represent a very attractive process by which certain non-compliant taxpayers can come into compliance without penalty (for those living outside of the U.S. who meet a non-residency test) or with a 5 percent miscellaneous offshore penalty for those residing inside the U.S. […]
OVDP TO END ON SEPT. 28, 2018 – ACT NOW ON UNDISCLOSED OFFSHORE ACCOUNTS
I don’t often post verbatim complete IRS pronouncements. This post is an exception, however, because the IRS Newswire Issue reprinted below contains an urgent message for those with unreported offshore income and / or foreign financial accounts who have not yet taken action to come into compliance. After September 28, […]
PARADISE LOST: THE “PARADISE PAPERS LEAK REVEALS MODERN DIGITAL AGE TRUTHS – (1) ALL FINANCIAL RECORD CAN BE HACKED. 92) THERE ARE NO CYBER SECRETS. AN OVDP SOLUTION FOR OFFSHORE NONCOMPLIANCE
In John Milton’s epic biblical poem “Paradise Lost,” the fall of Man is depicted. The Devil is banished to Hell. The Modern Wealthy Man has had his own fall. The morality-play today devolves around tax-evasion and the loss of privacy. Keeping one’s financial affairs secret from the masses, sometimes for […]
THE HOUSE TAX REFORM BILL WOULD REPEAL THE ALIMONY DEDUCTION
The House of Representatives has revealed its Tax Reform Plan encapsulated in The Tax Cuts and Jobs Act (HR 1) The House Committee on Ways and Means Section by Section Summary describes the provision on Alimony as follows: Sec. 1309. Repeal of deduction for alimony payments. Current law: Under current […]
DEPARTMENT OF JUSTICE ANNOUNCES FBAR GUILTY PLEA OF GREEN CARD HOLDER
On October 26, 2017, Hyung Kwon Kim (Kim), a Greenwich, Connecticut man pleaded guilty to failing to report funds he maintained in foreign bank accounts to the Department of Treasury. The DOJ Press Release was announced Acting Deputy Assistant Attorney General Stuart M. Goldberg of the Justice Department’s Tax Division, […]
WHEN IS A JOINT RETURN DEEMED TO HAVE BEEN FILED?
The Tax Court decision in Victor A. Edwards v. Commissioner, TC Summary Opinion 2017-52 contains an instructive discussion of the rules applicable to determining whether a valid joint return has been filed. Bear in mind that this is a summary opinion and therefore may not be cited as precedent. The case analysis […]
U.S. EXPATRIATES FEEL ABUSED BY FATCA AND OPPRESSIVE TAX REPORTING REGIME
I receive calls every day from U.S. Citizens living abroad who have recently learned that they are not compliant with U.S. tax filing and reporting obligations. They are angry, confused and frustrated. They’ve never heard of these requirements before getting the bad news that they could be subject to draconian […]