The Fifth Amendment’s Essential Role in Offshore Audits
We’ve all seen Matlock reruns, haven’t we? We all sat through a civics class in high school, didn’t we? So we all know what the Fifth Amendment is, right? Therefore, is there any reason at all to finish this article? Before we can begin to understand how the Fifth Amendment applies in offshore tax cases, […]
Examining The ‘Foreign’ Tax Home Requirement
This appeared in the January 26, 2017 edition of Global Tax Weekly. Click here.
FATCA Brings End To Switzerland’s Time- Honored Tradition Of Bank Secrecy
This article appeared in the January 19, 2017 edition of Global Tax Weekly. Click here.
Justice Department Reaches Final Resolutions Under Swiss Bank Program
The Department of Justice issued the following press release back on December 29, 2016: The Department of Justice announced today that it has reached final resolutions with banks that have met the requirements of the Swiss Bank Program. The Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States, […]
FATCA Brings End to Switzerland’s Time-honored Tradition of Bank Secrecy
Click here.
Essential Elements of Tax Crimes
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Tax Crimes That The Government Relies Upon in offshore bank tax prosecutions
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Understanding the PFIC Rules and the Implications of Owning Foreign Mutual Funds
Attached is an article that I co-authored with Randall Brody, EA of Tax Samaritan that appeared in the November-December 2016 issue of “EA Journal.”
Getting To Know Form W-8BEN And What It’s Used For
Non-U.S. persons must pay U.S. tax on certain kinds of income they receive from U.S. sources. Typically, the income is taxed at a flat rate of 30%. The only exception to paying the full amount is if an income tax treaty exists between the U.S. and another country that authorizes a lower rate of tax. Let’s take a slight […]
Survey of Citizens Renunciation Intentions: A Lannister Always Pays His Debts, but Americans Change Kingdoms to Evade Taxation
After the IRS shouted “Dracarys” in 2010, the Foreign Account Tax Compliance Act (FATCA) breathed fire on American taxpayers, causing more chaos than the destruction immortalized in the Rains of Castamere. The law mandates that U.S. citizens, including those residing outside the country, report their financial accounts outside the U.S. The IRS didn’t stop there; […]