Entries by Tax Attorney

“Quiet Disclosure” of Foreign Accounts- Not So Quiet As It Seems

There are strong indications that going forward, the IRS will be cracking down more stringently on the practice of “quiet disclosures”.  Under a quiet disclosure, a taxpayer through normal IRS filing channels files new or amends past tax returns and FBAR’s to report previously unreported offshore accounts and foreign income in an attempt to avoid […]

Swiss Banks Rush to Meet U.S. Disclosure Deadline – Urge Their American Account Holders to Come Forward with Disclosure to the IRS

The Swiss government has been urging about 300 Swiss banks to come forward and disclose their American account holdings to the U.S.   The deadline set by the U.S. Department of Justice (“DOJ”) for the Swiss banks to participate in a voluntary program whereby they disclose assets of their American clients was December 31, 2013.  By […]

Time Limits on IRS Collection Efforts

Once you have an assessment our outstanding balance with IRS, the IRS is notorious for aggressively pursuing collection action by issuing levies on your bank accounts and sources of income.  Their efforts though cannot last forever. It’s a little-known fact that the IRS has a Statute Of Limitations on collecting amounts owed to IRS. If […]