Firm News

On January 30 and February 1,  I chaired a FATCA conference in Miami which was put on by a company called Marcus Evans out of London which is a for profit business. The conference was attended by a diverse group of banking officers, in-house tax counsel to large...

Last week, in a move many practitioners found shocking, the Internal Revenue Service informed selected tax attorneys that some of their clients who had been accepted into its offshore voluntary disclosure initiative with once-secret offshore accounts in Bank Leumi,...

I will be chairing an international conference in Miami this week on FATCA compliance. Here is an advance read on some of the issues I plan to discuss with the people who will be coming from all over the Caribbean and Latin America. With the publication of the Final...

As taxpayers and practitioners get ready to start a fourth year of dealing with the IRS in the area of offshore voluntary disclosures, it's fair to ask, where is IRS Appeals in all of this? For those who don't know, the IRS Appeals Division has a proud history dating...

Mention retiring Commissioner of Internal Revenue Doug Shulman and some Americans abroad see red and misdirect their anger at him over FATCA and the IRS’s new focus on FBAR-only audits and enforcement. Last week he gave his goodbye speech and listed what he considers...

Cal CPA ABC Mixer at the Sutter Club in Sacramento. The "ABC" stands for attorneys, bankers and CPA’s. The event was so successful this past February that our good friend Dave Motes, who has organized this event for years, decided to do it twice a year. I have...

One of the most common problems we see in our practice is the plight of recent immigrants to the United States who are never told in citizenship class that the United States taxes its citizens and residents on their word-wide income and that they have to file FBAR’s...

There is an often over-looked and perhaps little-known IRS rule in the twenty two pages of fine print of the IRS Frequently Asked OVDI Questions which may fit the facts of many thousands of Americans living abroad. If you live abroad and have $10,000 or less in U.S....

Even before the ink dries on the few agreements foreign banks may have entered into with the IRS to be a withholding agent for the US government, the rules are changing drastically. Major western European countries have already entered into agreements with the United...

On August 31, 2012, the IRS published the new procedures first announced on June 26 regarding offshore voluntary disclosures.  This is essentially a recognition on the part of the IRS that there are certain “no brainer” fact scenarios which qualify for relief from the...