Entries by Tax Attorney

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 […]

What to do if you failed to declare your closed foreign bank account that was open within the last six years?

Even though you may have closed your foreign accounts years ago, the IRS can go back as far as six years to impose penalties and perhaps even criminal prosecution for taxpayers who did not disclose their worldwide income on their U.S. income tax returns nor report their foreign accounts to the U.S. Treasury. IRS has […]

Classification of Taxpayers for U.S. Tax Purposes

U.S. law treats U.S. persons and foreign persons differently for tax purposes. Therefore, it is important to be able to distinguish between these two types of individual taxpayers.  This area of the tax law can be quite confusing. For an individual to be classified as ”United States person” for tax purposes means he or she […]