Entries by Tax Attorney

If you have tax problems, why should you hire a tax attorney instead of calling IRS on your own?

Through my years in this profession, that is one of the most commonly asked or thought about questions. Usually a taxpayer’s attention to his or her tax problems stems from a notice generated by some department of the IRS (which may look extremely intimidating) demanding that the taxpayer immediately contact either the Revenue Officer or […]

Taxpayer Scores $862,000 from IRS after Tripping over a Phone Cord

A taxpayer who met with a Revenue Officer at an Internal Revenue Service office on Long Island successfully sued the IRS for $862,000 after he was injured by tripping over a phone cord. William Berroyer claimed in his lawsuit that he could no longer play golf or have intimate relations with his wife more than […]

Foreign Trusts – Filing Requirements

All U.S. taxpayers who have an interest in, or signatory or other authority over foreign trust accounts must file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), if the aggregate value of the foreign trust accounts exceeds $10,000 at any time during the calendar year.  As of October 1, 2013 the FBAR […]

Americans with Israeli Bank Accounts- Under Heightened Scrutiny in 2014

Americans with Israeli bank or other financial accounts could face a tough tax season in 2014 if they do not come forward and disclose their assets to the IRS.  Recently, Israeli banks have come under increased scrutiny by the IRS in regards to disclosing the accounts of their American clients.  In particular, three Israeli banks- […]

“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 […]