We are pleased to republish with permission, a Tax Notes article my Partner Ryan Carrere and I published on April 27, 2015. For those practitioners with clients with offshore financial accounts, the filing season isn’t over until after the June 30, 2015 due date for...
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Tax Justice for Americans Abroad: IRS Needs to Adopt a “Same Country Exception” to Exempt Americans Living Abroad from the FATCA Dragnet
We are pleased to republish with permission, the Tax Analysts article below written by Charles Bruce, a fellow Professional Advisory Council member for American Citizens Abroad. ACA is a powerful non-partisan, non-profit volunteer association based in Geneva and...
IRS TO ISSUE MORE TICKETS TO THE TAX COURT IN 2015
In a little noticed IRS revision to one of its form letters just last August,[1] the IRS has signaled that it will be issuing more 90-Day Letters[2] in certain cases where a taxpayer fails to satisfy a revenue agent’s request for additional facts in an examination....
A Look at the IRS Reorganization from the Inside: A Personal View of the old Sacramento District
My last blog of November 3rd generated some lively emails and comments on LinkedIn and it appears as though I hit a nerve. There are plenty of IRS veterans still in place as well as alumni around who remember what the IRS field offices were like both before and after...
SIXTEEN YEARS LATER: WAS THE 1998 IRS REORGANIZATION GOOD GOVERNMENT OR BAD GOVERNMENT?
One of the best pieces of writing recently about the IRS’s continued downward slide, is Professor Emeritus Frank Wolpe’s white paper[1], which was published by the Taxation Section of the American Bar Association in its NewsQuarterly, 2014 Winter Issue, as its...
Republication of Moodys Gartner Tax Law’s Blog “Updated IRS Streamlined Filing Program: Snowbirds Beware”
We are pleased to republish with permission from Roy Berg, on behalf of Moodys Gartner Tax Law, an excellent blog, which pertains particularly to “Canadian snowbirds.” As the article points out, the new Streamlined Procedures present an anomaly for “snowbirds” under...
“Practitioners Debate Fairness Of Lack of OVDP Retroactivity” by Andrew Velarde
Here is an interesting article by Andrew Velarde, published with permission from Tax Analysts, on Voluntary Disclosures which I thought you might find interesting. Practitioners Debate Fairness Of Lack of OVDP Retroactivity By Andrew Velarde — [email protected] The...
Steve Mopsick and Ryan Carrere Are Pleased To Announce That Kathleen Donelan-Maher Is Joining Them In Partnership
Mopsick Tax Law is pleased to announce that Kathleen Donelan-Maher is joining Ryan Carrere and Steve Mopsick as a law partner. Before joining MTL, Kathleen enjoyed a long and multi-faceted career in the accounting and tax fields. Kathleen started her academic career...
FATCA ENFORCEMENT, VOLUNTARY DISCLOSURES, AND THE STREAMLINED EXPRESS: WINNERS AND LOSERS
The June 18th IRS announcements have added some new words and dates to the debate, but for the practitioner, the analysis of the issues with regard to offshore compliance is still the same. Even as some of the decision points have shifted in representing clients...
The New Streamlined Foreign Offshore Procedures Contain a Trap for Unwary Americans Abroad
Americans abroad should be pleased that IRS Commissioner John Koskinen kept his word when he advised us on June 3, 2014, to “stay tuned” in anticipation of new OVDP guidelines. The new guidelines make a distinction between those taxpayers who have been acting...