Chief Counsel Advice 201719026
In a recently published Chief Counsel Advice, the IRS chief counsel’s office offered advice to taxpayers participating in its tax amnesty programs regarding the issue of whether refunds for past…
Read MoreIRS and Court Decisions
Reviews of court rulings and IRS decisions affecting U.S. expats, especially on FBAR penalties, Form 5471 and the foreign earned income exclusion.
Reporting of Foreign Corporations
In a new decision, the Tax Court upheld heavy penalties imposed by the IRS on a U.S. expat taxpayer who failed to report his ownership in two foreign corporations. The decision certainly serves as a…
Read MoreFailed to File FBAR
If you thought FBAR penalties were more bark than bite, a recent U.S. District Court case is sure to change your mind.
Read MoreThe Whistleblower Program
In what is being hailed as a landmark decision, the U.S. Tax Court recently sided with a pair of whistleblowers who provided information that assisted the U.S. government in a high-stakes tax evasion…
Read MoreFailure to Read the FBAR Instructions
As this year’s tax season forges ahead and filing deadlines quickly approach, we’d like to remind our readers about the importance of getting your taxes done right. This is especially relevant for…
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