Entries by Tax Attorney

IRS Announces New Initiative To Target Unreported Indian Accounts In Northern California

Late last year at a California Bar conference, an IRS official stated that the IRS will start in 2014 a new Indian initiative targeted at individuals with undeclared Indian accounts. Nicholas Connors, a supervisory revenue agent with the IRS small business/self employed division stated that the IRS will soon “begin examining US taxpayers suspected of holding undeclared accounts […]

Credit Suisse Helped Wealthy Americans Cheat The IRS

A Senate Report just issued states that Swiss banking giant Credit ­Suisse helped wealthy Americans hide billions of dollars from U.S. tax collectors. Credit Suisse chief executive Brady W. Dougan and Deputy Attorney General James M. Cole recently appeared at a Congressional subcommittee following the issuance of the 175-page report.  The report was issued after […]

Ten Reasons Against Continued Non-Disclosure Of Your Foreign Income And Foreign Accounts.

As an incentive to drive taxpayers into the Offshore VoluntaryDisclosure Initiative (OVDI) the U.S. government continues to ramp up its efforts in searching for and flushing out income tax evaders who continue to utilize undisclosed foreign accounts, entities or assets to hide income. Because the IRS has devoted massive resources to publicizing the reporting requirements […]

Is “Present Tax Year Only Disclosure” your answer to IRS Voluntary Disclosure?

We handle a lot of inquiries from taxpayers trying to figure out if they really need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Tax preparers have also questioned us on what to do now that they have learned that a client has never reported their foreign income and foreign accounts.  Some tax advisors are […]

Final FATCA rules are issued – Deadline Is July 1, 2014 For Foreign Banks To Disclose U.S Account Holders To IRS

Last week the IRS released a large package of regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree […]

IRS Grants Limited Relief For U.S. Persons Owning Mexican Property In A Fideicomiso

In June 2013, the IRS handed down Rev. Rul. 2013-14 which states that Mexican Land Trusts (MLTs), also known as “fideicomisos”, are not trusts for purposes of IRS tax law.  Prior to the ruling, there was confusion over whether these MLTs were trusts subject to onerous tax reporting requirements involving foreign trusts.  As a result […]

Go For The Gold And Pay Your Tax – Olympic Medals Taxable

While millions of Americans were glued to their televisions to watch American athletes compete in this year’s Winter Olympics, the Internal Revenue Service was quietly getting ready to make sure that all our Olympic winners pay taxes on their victories. It’s true. The Internal Revenue Code mandates that If you win a prize in a […]

IRS Warning: Beware Of Sophisticated Fraudulent Tax Collection Notice Scam Targeting Taxpayers

From time to time the IRS issues consumer warnings on the fraudulent use of the IRS name or logo by scamsters trying to gain access to consumers’ financial information in order to steal their identity and assets. When identity theft takes place over the Internet, it is called phishing. Suspicious e-Mail/Phishing Phishing (as in “fishing […]

Your Foreign Bank Is Disclosing You To The IRS

The IRS has various ways to find out about international or overseas bank accounts.  The Foreign Account Tax Compliance Act (“FATCA”) which was passed by Congress in March 2010 requires foreign financial institutions to register with and report to the IRS certain information about their U.S. account holders. The foreign financial institutions include, but are […]