International Tax Blog: Articles, News & Updates

Taxpayer Indicted for Streamlined Offshore Tax Fraud: New 2021

Contents1 Taxpayer Indicted for Streamlined Offshore Tax Fraud2 Criminal Prosecution for Willful Streamlined Disclosure3 Businessman Indicted […]

Delinquent International Information Return Submission Procedures

Contents1 IRS Delinquent International Information Return Submission Procedures2 Use a Board-Certified Tax Law Specialist3 Fees for […]

Streamlined Filing Compliance Procedures: How to Apply 2021

Contents1 Streamlined Filing Compliance Procedures 2 Purpose of the IRS Streamlined Filing Compliance Procedures3 Who is Eligible […]

Streamlined Domestic Offshore Procedures: (New) 2021

Contents1 IRS Streamlined Domestic Offshore Procedures (SDOP)2 Eligibility for Streamlined Domestic Offshore Procedures3 How to Submit […]

IRS Voluntary Disclosure Program & New OVDP

Contents1 New IRS Voluntary Disclosure Program & OVDP Updated2 2020 IRS Voluntary Disclosure Program3 No IRS […]

Streamlined Foreign Offshore Procedures

Contents1 IRS Streamlined Foreign Offshore Procedures (SFOP)2 Eligibility for Streamlined Foreign Offshore3 How to Submit to […]

Flat-Fee or Hourly Streamlined Offshore Filing Lawyer?

Contents1 Flat-Fee Streamlined Filing Lawyers2 Low Up-Front Hourly Fee Bait-and-Switch for Streamlined Cases3 Benefits of Flat-Fee […]

Reasonable Cause for Offshore Penalties FBAR & FATCA: New 2021

Contents1 Reasonable Cause for Offshore Penalties FBAR & FATCA2 FBAR & FATCA Penalties3 Reasonable Cause or […]

Who is a Nonresident Alien for US Tax?

Contents1 Who is a Nonresident Alien for US Tax?2 Worldwide Income vs US-Sourced Income3 Substantial Presence […]

FBAR Instructions: International Foreign Account Guide

Contents1 FBAR Instructions2 10-Step FBAR Instructions Guide3 25 Frequently Asked FBAR Questions FBAR Instructions FBAR Instructions: […]

Reckless Disregard and Schedule B: Kimble & A Grain of Salt

Contents1 Reckless Disregard and Schedule B2 Kimble Background: Swiss Banks and Numbered Accounts3 Kimble Entered OVDP/OVDI […]

What is an Eggshell Audit for Tax Returns

Contents1 What is an Eggshell Audit?2 Eggshell Tax Audit3 Reverse Eggshell Tax Audit4 Be Careful During […]

Who Must File FBAR for Virtual Currency Offshore Ownership

Contents1 Who Files FBAR for Virtual Currency Offshore Ownership2 Do You Need to File FBAR for […]

Cryptocurrency John Doe Summons May Uncover Taxpayer Identities

Contents1 Cryptocurrency John Doe Summons Reveals Crypto Fraud Identities2 IRC 7609(f)3 IRM 25.5.7.1.1 (06-04-2020) – John […]

How to Disregard a Foreign Entity for US Tax Purposes: Form 8832

Contents1 Disregarding a Foreign Entity for US Tax Purposes on Form 88322 What Type of Foreign […]

FBAR Appeals: What’s the Process for Appeals

Contents1 FBAR Appeals2 IRS Office of Appeals & FBAR3 FBAR Appeals & the Penalty Abatement Process4 […]

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