Blog Profile / Tax Problem Attorney Blog

Filed Under:Business & Finance / Taxes
Posts on Regator:132
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Archived Since:March 8, 2011

Blog Post Archive

Even the IRS is Confused About Australian Superannuation Accounts

The other day our tax lawyers posted the materials we have received so far in response to our FOIA request regarding Australian Superannuation accounts and other foreign retirement plans. The most interesting thing we found was a series of emails between various technical specialists in the IRS’ Offshore Compliance Group, IPN OVDP Coordinator. (By the […]

Brager Tax Law Group Receives FOIA Documents on Australian Superannuation Accounts, and Other Foreign Retirement Plans

Our tax attorneys have had many clients with Superannuation accounts in Australia. For those of you not familiar with Superannuation accounts, these are the Australian version of our tax favored retirement plans. These Superannuation accounts, sometimes referred to as Supers, can be very problematic for immigrants from Australia to the U.S. because they may, or […]

The Failure to File Taxes in a Timely Manner May Impact a Taxpayer’s Eligibility for Bankruptcy Discharge (Part Two)

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 taxes filed even one day past assessment would result in the nondischargeability of the debt in bankruptcy. In this post we will […]

The Failure to File Taxes in a Timely Manner May Impact a Taxpayer’s Eligibility for Bankruptcy Discharge

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 consequences. In a recent unpublished opinion, In re Kevin Wayne and Susan Martin, EC-14-1180-KuKiTa (9th Cir. BAP 2015), the Bankruptcy Appellate Panel (BAP) provided some guidance […]

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 these serious penalties, a proposed provision contained within the pending 2015 highway & transit funding bill, aka the Surface Transportation Reauthorization and Reform Act […]

Small Business Owners Who Doctor the Books or Misuse Company Funds for Personal Expenses Can Face Serious Tax Charges

Small business owners are the dedicated and hardworking individuals that make our economy strong and our country great. On the whole, many small business owners lack the resources or processes and procedures to ensure that they and their company remains fully compliant with all tax obligations. Unfortunately for owners of small businesses, the IRS is […]

More Swiss Banks Enter Into Non-Prosecution Agreements While Offshore Penalties Soar

One of the top priorities for the IRS and Department of Justice has been the focus on offshore financial accounts held by U.S. taxpayers, and used to avoid or defeat the assessment of tax. Underscoring the need for an increased focus on offshore tax enforcement is a 2008 U.S. Senate report showing that the use […]

Accidental American Status Can Lead to Huge Tax Liabilities

Status as an American citizen, legal permanent resident, and other circumstances can result in a tax obligation to the United States government. Individuals who are confused about their status should never wait to see how things play out. Rather, they should investigate diligently to determine their status and whether any tax obligation is owed to […]

U.S. and Turkish Governments Will Share Tax Information Under FATCA

In yet another sign of the rapidly expanding reach of FATCA and the U.S. government’s increased access to account data from around the world, the Turkish government reached a reciprocal information sharing agreement with the United States government. The bottom-line here is that taxpayers holding undisclosed accounts and assets in Turkey are now significantly more […]

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 receiving notice that you need to take action to correct a past tax filing or past tax […]

The Length of Time You Are Subject to an IRS Audit May Have Just Doubled

The U.S. Tax Code is, essentially, in a constant state of flux. While there are certain bedrock principles, such as the obligation to file and pay taxes, particularities regarding both substantive and procedural handling of tax issues can change with time. Decisions made by judges, changes to the Internal Revenue Code by acts of Congress, […]

Indian Government Agrees to FATCA & Tax Information Sharing with United States

On July 9, 2015, the United States and Indian governments announced that they had entered into a Foreign Account and Tax Compliance Act (FATCA) agreement. FATCA is a U.S. law that has been described by some as a “global banking law.” The reason for this characterization is because the law requires banks and other financial […]

Foreign Bank Account Report (FBAR) Filing Date Extended by HR 3236

On July 31, 2015, President Barack Obama signed into a law HR 3236 a highway funding bill. Buried in the Bill is a provision which changes the filing date for Foreign Bank Account Reports (FBARs) to April 15th. Up until now the due date for the FBAR, which must be filed electronically on FinCEN Form […]

How Long of a Prison Sentence Can Someone Face for Tax Fraud?

As many tax controversy attorneys can state, tax problems can lead to major issues including a tax audit and even criminal tax charges. Even though tax problems are typically serious matters there are certain tax crimes that stand out even among serious offenses. Tax Evasion and tax fraud involving the use of stolen identities and […]

How Many Years Back Can the IRS Go in its Search for Tax Fraud?

The IRS and Department of Justice have cracked down on tax fraud and tax evasion regardless of its form. However, in recent announcements the Department of Justice has revealed its targeted enforcement focus on business payroll tax fraud, offshore tax fraud including non-compliance with FATCA & FBAR, Stolen Identity Tax Return Fraud (SIRF), and other […]

IRS Issues New FBAR Penalty Guidance (SBSE-04-0515-0025)

On Friday the IRS released new guidance on how examiners should determine the amount of any penalty for the failure to file an FBAR (Report of Foreign Bank Account, FinCEN Form 114). The guidance is effective for all open cases as of May 13, 2015. It does not appear to apply directly to cases in […]

Have You Received a Deficiency Notice or Another Letter Regarding Tax Problems From the IRS?

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 except for the name and address of the Internal Revenue Service emblazoned upon it. Maybe you tear it […]

U.S. Expatriates and International Workers: Beware of Exceptions to the Foreign Income Exclusion

U.S. citizen, resident aliens and others who are U.S. taxpayers face a unique mode of taxation in the United States. That is, U.S. taxpayers are taxed on their worldwide income regardless of where it was earned. Predictably and understandably, this method of taxation results in many expatriates worrying about whether they will face double taxation […]

Tax Problems Following a Divorce or Marital Problems? Innocent Spouse Relief May Be an Option

Many married couples find it advantageous to file a joint tax return rather than filing separately. This comes as no surprise as the federal government has built a number of tax advantages for married couples filing jointly into the tax code. These benefits include: Depending income distribution, a lower rate of taxation than they would […]

Failure to File Taxes? Expats can face a Customs Hold, Failure to File Penalty, and a Failure to Pay Penalty

If you are living in the United States it can be difficult to miss the numerous announcements and pronouncements of the impending April 15th tax deadline. And yet, every year thousands of US taxpayers will fail to file and pay taxes. There are a variety of reasons for this failure. These reasons can include situations […]

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