Entries by Tax Attorney

Top Questions On IRS Audits

Many people have approached me with questions on IRS audits and so I have taken the most popular questions and laid them out in this blog with my response. 1. I received an IRS Notice informing you that your return has been selected for examination. What should I do? The fact that your return has […]

Received A Notice Of Deficiency To Appeal IRS Proposed Adjustments To The U.S. Tax Court? Let us help you

Before adjustments from an audit can be finally assessed, a taxpayer must be given the right to appeal to the United States Tax Court if the taxpayer should disagree with the findings of the IRS audit. The Appeals Office (or in certain cases the IRS agent) will issue a “90-day Letter” to a taxpayer, which […]

FBAR: Goodbye Form TDF 90.22-1 and Hello FinCEN Form 114

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes. On September 30, 2013, FinCEN posted on their internet site, a notice stating that the […]

Opting-Out Of OVDI – Top Questions Answered

IRS has established programs for taxpayers to voluntarily come forward and disclose unreported foreign income and foreign accounts under what the IRS calls the Offshore Voluntary Disclosure Initiative (OVDI). On January 9, 2012 the IRS announced the terms of the 2012 OVDI which requires that taxpayers: (1) File 8 years of back tax returns reflecting […]

Bitcoin Tax Reporting Requirements

Bitcoin has been in the news frequently lately, particularly since the collapse of the Japanese-based Bitcoin exchange, Mt. Gox. Bitcoin is a digital currency and peer-to-peer payment system created in 2009. Since 2009, the use of bitcoins has expanded significantly. Bitcoins can be bought and sold for various currencies, generally through a series of online […]

What To Look For In Selecting A Tax Attorney For OVDI / FBAR

With the full enforcement of the Foreign Account Tax Compliance Act (“FATCA”)starting July 1, 2014, all of the foreign banks have been requiring their U.S. account holders to disclose their social security numbers and other information so that the foreign bank may comply with this law and report their U.S. account holders to the IRS […]