The Foreign Account Tax Compliance Act (FATCA), a U.S. law passed in 2010 that requires foreign financial institutions to exchange information with the IRS about American account holders, is set to face challenges in both the courts and in Congress. Since 2012, the Treasury Department has negotiated Intergovernmental Agreements with […]
“Don’t look back” is a memorable line in literature. It is the title, for example, of a notable documentary from the 1960s about a high-profile British concert tour by the enigmatic singer Bob Dylan. We may all agree that, in general, it is best to focus on the future. But […]
Two former Credit Suisse bankers have received extraordinarily light sentences after pleading guilty and cooperating with the Department of Justice in its case against the Swiss Bank. Josef Dörig and Andreas Bachmann were each sentenced to five years’ probation and a fine, sentences that are substantially lower than the recommendations […]
Swiss bank BSI SA has admitted to helping U.S. clients evade taxes and entered into a non-prosecution agreement with the U.S. Department of Justice, in a deal that requires the bank to pay a $211 million penalty and turn over the names of 3,000 American account holders. They are the […]
If federal authorities accuse you of tax fraud, the steps you and your attorney take in response are crucial. Given the complexity of the tax code, it is important to get counsel from an experienced tax attorney who knows how to defend and resolve criminal tax charges. In this post, […]
In the first part of this post, we outlined the basic considerations involved in defining when an organization is “closely held” for tax purposes. In this part of the post, we will look in more detail at how the Tax Court and the IRS have differed recently in interpreting and […]
By Brown, PC of Brown, PC posted in Offshore Accounts/International Tax Disputes on Thursday, March 26, 2015. Last summer, the IRS announced sweeping changes to its ongoing offshore compliance initiatives. The biggest change was the announcement of new Streamlined Compliance Procedures. Under these procedures, eligible taxpayers who resided in the […]
The Treasury Department announced a Final Rule this week to avoid having to reveal to PTIN holders the names of agencies that have requested their files. The purpose of the rule is to prevent these individuals from finding out that they are under investigation and destroying evidence. This new rules […]
Closely held businesses can sometimes seem synonymous with their owners. But for tax purposes, there are important respects in which that is not true. In this post, then, we will ask and address the following question: How does the IRS define a closely held corporation? The question is timely because […]
The IRS filed a federal tax lien against Robert De Niro, stemming from $6.4 million in unpaid tax liabilities from the 2013 tax year. The lien was filed on February 3, 2015, and the actor paid the balance in full three weeks later. The 71 year old actor, best known […]