Entries by Tax Attorney

Taxpayer Reporting Requirements for Foreign Real Estate

Many U.S. taxpayers do not realize that they must report their worldwide income, regardless of whether they are living in the U.S. or abroad.  If you are a U.S. Citizen or resident alien, you must report your worldwide income from whatever source, subject to the same income tax filing requirements that apply to U.S. Citizens […]

Should your really believe those companies that advertise that they can settle your IRS debt for pennies on the dollar?

Through my years in this profession, that is a commonly asked or thought-about question. We call these companies “Offer Mills”.  These companies which have no track record or history come in and out rather quickly and are never associated with any individual willing to put his or her name to the company and what the […]

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 […]