The Streamlined Procedures: Traps for the Unwary
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Clearing Up the Confusion Between the events that trigger an increase in the offshore penalty from 27.5% to 50% with the events that disqualify a taxpayer from participating in OVDP altogether
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A Primer on DOJ’s Swiss Bank Program
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What Should I do if I receive a “Declaration of Consent” Form from My Swiss Bank?
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The Mechanics of How Information Gets Exchanged
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The FATCA Tornado Hits Ground
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Your Lifeline for Form 8938
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State Offshore Voluntary Disclosure – Because One Tax T-Rex Wasn’t Enough
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Challenging the IRS’s Assertion of the Non-willful FBAR Penalty: A New Hope
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Calculating FBAR Penalties Under the Penalty Mitigation Guidelines
Example 1: Assume that John has an undisclosed offshore account with a maximum account balance of $ 40,000 (USD) in tax year 2012. He decides to make a quiet disclosure. Assume that he otherwise satisfies the conditions for penalty mitigation. The best way of analyzing this problem is to do so in three-steps: Step 1: […]