Taking A Cooperative Approach To Your Legal Issues
A reader posted the following on another web site asking for my input, my response is below his post: “IRC code 6677 title 26” Published on August 28, 2012 by mach73 in Issues regarding US persons abroad. “Hoping Mr. Mopsick will chime in on this, but it seems every...
FATCA was enacted over two years ago but apart from the requirement to register all “specified foreign financial assets” with the IRS on last year’s (2011) tax returns, the punishing 30% withholding provisions have yet to kick in for nonparticipating foreign financial...
Recently, a for profit promoter in London was able to convince the IRS Office of Chief Counsel to allow two of its very qualified senior attorneys to speak via satellite link to a withholding congress group about the new FATCA Regulations. This presentation has been...
In May of this year the IRS announced some changes to the Offer in Compromise (OIC) program. The IRS changes include: 1. How they calculate future income; 2. Allowing certain student loan payments; 3. Allowing taxpayers payments for delinquent state or local taxes; and 4. Expanding the allowable living expense standard. I see some practitioners touting these changes as though…
How To Make The Government Listen To The Plight Of Americans Abroad And Recent Immigrants To The United States- What Works; What Doesnt One of the hottest issues in tax compliance today is how to make the U.S. government address the unintended consequences of the...
We recently blogged and published an article about Tax Justice for Americans abroad with little or no economic connection to the United States. In our article, we argued that paying a 27.5% tribute to the IRS under the voluntary disclosure program made no sense for...
My recently published article in Tax Notes Today The potential for IRS overreaching in its enforcement of the Bank Secrecy Act (FBAR's) and FATCA has created a firestorm of fear and anxiety in the world-wide American expatriate community. The IRS has done a good job...
New Filing Procedure For Americans Abroad; Too Little, But Not Too Late On June 26, 2012, the IRS announced a new filing compliance procedure for non-resident U.S taxpayers. The procedure provides that current non-residents including dual citizens, who have not filed...
This past week, the Isaac Brock Society published another interesting thread which basically asked if Obama deserves to be re-elected in light of FATCA, OVDI, and FBAR's. Here are some slightly edited comments Imposted: (You can see the origional post here) The title...
What expenses will the IRS allow when determining ability to pay delinquent tax debts? The IRS has established expense standards for several categories of expenses. In order to claim an expense, taxpayers must show the expense meets the “necessary expense test.” The necessary expense test is defined as expenses that are necessary to provide for a taxpayer’s (and his or…
