Blog Profile / Tax Problem Attorney Blog

Filed Under:Business & Finance / Taxes
Posts on Regator:139
Posts / Week:0.5
Archived Since:March 8, 2011

Blog Post Archive

Why Hire a Tax Attorney for a Tax Return Audit?

When you are notified that you have been chosen for a tax return audit, you may not be sure what to do next. How do you prepare for an intense inspection of your tax documents and ensure you can answer any questions the tax auditor may have? Hiring a tax attorney can be the best […]

Tax Considerations When Living Abroad

Tax season is difficult enough. When living abroad, it can become even more complicated. As a U.S. citizen, you must file a tax return with the IRS, regardless of where you are living in the world. You also may need to pay and file taxes in the country where you live. Here are a few […]

IRS Appeals Division Slashes Taxpayer Rights

The IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM), blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone except under certain specific enumerated circumstances. Show More Summary

Protecting Your Assets from IRS Seizure

Owing the IRS money can result in many consequences, including losing assets to an IRS seizure. No one wants to lose their home, vehicle, bank accounts, or other assets due to a dispute regarding unpaid back taxes. It is important to understand how to protect your assets from IRS seizure if you are struggling with […]

Tax Evasion Charges? Know Your Rights

One of the most serious crimes one can face from the IRS is a charge of tax evasion. If convicted, a person can face a felony charge, large fines and prison time. If you have been charged with tax evasion or are under criminal investigation for tax fraud, you do not want to face this […]

Israel-United States Tax Treaty Doesn’t Insulate Capital Gains of Israeli Citizens from U.S. Taxes

Many U.S. citizens who are also legal permanent residents of Israel may be confused about their tax obligations in the U.S. They may also have questions about their duty to file Foreign Bank Account Reports (FBAR) FinCEN Form 114. One of these issues was on display in the recent U.S. Tax Court case of Cole […]

IRS Taxpayer Advocate Releases Mid-Year Report; Dings IRS on Levying on Retirement Accounts

The Taxpayer Advocate is a tireless champion of taxpayer rights. The Taxpayer Advocate is required by law to issue reports to Congress. Her most recent mid-year report was recently released. One of her issues was that the IRS continues to levy on retirement accounts even though the IRS guidance to its revenue officers is “insufficient […]

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 […]

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