Application of Foreign Earned Income Exclusion to Civilian Contractors Working In Combat Zones (Part I)
This blog addresses the foreign earned income exclusion rules as they apply to civilian contractors, and other civilian employees, who work in foreign country combat zones. By “civilian,” I am specifically referring to individuals who are not employees of the United States or any agency of the United States. I. IRC Section 911 Foreign Earned […]
What Should A Swiss Banker Charged With Offshore Tax Evasion Do In The Wake of Raoul Weil’s Astonishing Acquittal?
The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a source of inspiration for dozens of others who find themselves in a similar situation – indicted and living in Switzerland. As a result, many have become emboldened to come out […]
IRS Unveils Updated List of Foreign Financial Institutions Or Facilitators That Trigger 50% Offshore Penalty In OVDP
The IRS recently updated the list of foreign financial institutions that trigger an enhanced penalty in OVDP. While the offshore penalty is generally 27.5% of the highest year’s aggregate balance during an eight year look-back period, to the extent that the taxpayer has an undisclosed foreign financial account with any one of the following banks at the time […]
How To Avoid Becoming The Next ‘Cooked Goose’ Gracing The IRS’s Offshore Tax Evasion Table
Is the Justification for the United States’ System of Worldwide Taxation A Hoax (Part II)?
In Part I, I argued that the benefits rationale – in terms of the public benefits received by citizens – was an unpersuasive justification for the U.S.’s system of worldwide taxation. I continue my rant in Part II, examining the practical effects of worldwide taxation on non-resident U.S. citizens. Through a labyrinth of “credits, deductions, […]
Should A Convicted Congressman Be Allowed To Keep His Seat In Congress And Continue To Receive Benefits?
Seems like politicians are having a problem staying out of trouble these days. The latest one to “bite the dust” did so in grand fashion, not failing to live up to the hypocrisy that makes for scintillating newspaper headlines. Who was this person? None other than United States Congressman, Michael Grimm. To use a cliché, […]
The Hunt For Snowbirds Is On – A Summary Of The IRS’s FAQ On Amnesty Programs For Non-Compliant Taxpayers
Bank Leumi Enters Into Non-Prosecution Agreement With Department of Justice; Agrees To Release More Than 1,000 U.S. Account Holder Names
In order to avoid a fate similar to UBS, Bank Leumi recently admitted to engaging in some tax “hanky panky.” One of the largest banks in Israel, Leumi admitted that it helped U.S. taxpayers evade their taxes. How so? By helping these individuals to hide their income and assets in offshore accounts in Israel and […]
Court Authorizes IRS To Issue John Doe Summonses For Records Relating to U.S. Clients Who Used A Shell Company To Conceal Offshore Accounts
On December 18, 2014, U.S. District Judge Vernon S. Broderick entered an order authorizing the IRS to issue summonses requiring the following companies to produce information about U.S. taxpayers who allegedly evaded federal taxes by using the services of Sovereign Management & Legal Ltd. (Sovereign): • Federal Express Corporation, doing business as FedEx Express, • […]
Is the Justification for the United States’ System of Worldwide Taxation A Hoax (Part I)?
The U.S. is one of the only countries left in the world that still taxes its citizens and residents on their worldwide income, regardless of where it is earned. In order to understand the debate, some background information about the different forms of worldwide taxation is necessary. There are two ways in which a nation may […]