International Tax Blog: Board-Certified Tax Attorney Specialist

The IRS Voluntary Disclosure Program Explained: New OVDP 2022

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

Foreign Bank & Financial Account Reporting (FBAR) Explained

Contents1 Foreign Bank & Financial Account Reporting (FBAR) Explained2 What to Know About FBAR Reporting3 General […]

When do You Have Reasonable Cause for Failing to File FBAR?

Contents1 Reasonable Cause for Failing to File FBAR2 Reasonable Cause for FBAR3 26 CFR 301.6724-1 FBAR […]

Tax Filing Requirements for Foreign Assets, Form 8938 (2022)

Contents1 Form 8938 2 Threshold Filing Requirements for Form 89383 Form 8938 Threshold Filing Requirements4 Foreign Financial […]

What are IRS International Reporting Penalties: Global Tax Counsel

Contents1 International Reporting Penalties 2 What are Assessable International Reporting Penalties?3 7 common International Reporting Form Violations4 […]

Form 5471: (New) Foreign Corporation Filing Requirements 2021

Contents1 Form 54712 Purpose of Form 54713 Who is Required to File Form 5471?4 What is […]

Delinquent International Information Return Submission Procedures

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

The (New) Streamlined Filing Compliance Procedures 2022

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 […]

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 […]

US v Solomon Court Vacates FBAR Judgment Against Defendant

Contents1 FBAR Judgment Vacated (For Now) in US v Solomon Round 22 Partial Summary Judgment 11/1/20213 […]

What are FBAR Filing Requirements for Foreign Bank Accounts?

Contents1 FBAR Filing Requirements2 General Instructions & FBAR Filing Requirements 3 General FBAR Filing Definitions4 Filing Information […]

Singaporean Solution Leads to Charges for Tax Evasion Conspiracy

Contents1 Singaporean Solution Leads to Charges for Tax Evasion Conspiracy2 Indictment Unsealed Against Six Individuals and […]

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