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January 2019

Treasury Expands Targeting Orders for Luxury Real Estate Transactions

2019-01-11T16:31:23+00:00

By: Eli S. Noff, Esq., CPA, Partner and Mary F. Lundstedt, Esq., Associate On January 13, 2016, exercising its authority under the Bank Secrecy Act, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders (GTOs), creating an anti-money-laundering data program which requires title insurance companies [...]

Treasury Expands Targeting Orders for Luxury Real Estate Transactions2019-01-11T16:31:23+00:00

Updated Guidance for IRS Voluntary Disclosure Practice

2019-01-09T16:13:26+00:00

By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate The objective of the recently expired Offshore Voluntary Disclosure Program (OVDP) enabled willful U.S. taxpayers with undisclosed foreign assets to become compliant with U.S. tax laws, while concurrently avoiding serious statutory civil penalties and practically removing any [...]

Updated Guidance for IRS Voluntary Disclosure Practice2019-01-09T16:13:26+00:00

October 2018

Offer In Compromise: Alternative to Collection

2018-12-06T09:33:54+00:00

By: Mary Lundstedt, Esq., Associate and Rebecca Sheppard, Esq., AssociateHave you ever considered filing an offer in compromise with the IRS to "settle your debt for pennies on the dollar"? Until recently, filing an offer in compromise was believed to create an automatic hold on collection action--i.e., the IRS would [...]

Offer In Compromise: Alternative to Collection2018-12-06T09:33:54+00:00

September 2018

Untimely CDP Arguments Worth Consideration

2018-12-13T17:52:30+00:00

By Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq. The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a [...]

Untimely CDP Arguments Worth Consideration2018-12-13T17:52:30+00:00

Coming Out of the Dark of International Tax Avoidance

2018-12-13T17:58:40+00:00

By: Eli S. Noff, Partner and Peter Palsen Jakarta, Indonesia - 1990 The aroma of my strong Java coffee blended with the smell of the dark teak paneling of the conference room of my client's office. I glanced at my U.S.-citizen client and then back to the two bankers who [...]

Coming Out of the Dark of International Tax Avoidance2018-12-13T17:58:40+00:00

August 2018

Be Vigilant When Hiring A Tax Preparer: Two Tax Preparers in Maryland Guilty of Filing False Returns

2018-12-08T22:06:43+00:00

By Glen Frost, Managing Partner and Mary Lundstedt, Esq., AssociateThe Comptroller’s Field Enforcement Division and the Criminal Investigations Division of the Maryland Attorney General’s Office, working in tandem, investigated and prosecuted two more Maryland tax preparers—resulting in guilty pleas. On July 24, 2018, Maryland Attorney General Brian E. Frosh [...]

Be Vigilant When Hiring A Tax Preparer: Two Tax Preparers in Maryland Guilty of Filing False Returns2018-12-08T22:06:43+00:00

The Foreign Account and Tax Compliance Act: What is FATCA?

2018-08-15T22:07:37+00:00

By: Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq., Associate  Brent Conrad In an effort to reduce persistent high unemployment rates resulting from the 2008 financial crisis, President Obama signed The Hiring Incentives to Restore Employment Act of 2010 (HIRE Act)1 to incentivize employers to hire and retain workers. Tax incentives provided [...]

The Foreign Account and Tax Compliance Act: What is FATCA?2018-08-15T22:07:37+00:00

July 2018

What’s Your Alien Tax Status and How Does It Affect Investment Property?

2018-12-06T08:49:38+00:00

By: Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq., Associate Brent Conrad For tax purposes, a non-U.S. citizen is either a nonresident alien or a resident alien. All aliens are considered nonresident aliens, unless they pass the green card test or the substantial presence test. A person meeting either [...]

What’s Your Alien Tax Status and How Does It Affect Investment Property?2018-12-06T08:49:38+00:00

IRS Actively Targeting Taxpayers for Passport Denial/Revocation – Notice CP508C

2018-12-08T22:18:40+00:00

By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate Several news outlets this week report that the U.S. State Department confirms that it has already acted on its part in the process and denied passports to an undisclosed number of taxpayers. Reports also confirm that the IRS [...]

IRS Actively Targeting Taxpayers for Passport Denial/Revocation – Notice CP508C2018-12-08T22:18:40+00:00

United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context

2018-12-08T22:20:05+00:00

By: Eli Noff, Partner and Mary Lundstedt On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government's suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of [...]

United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context2018-12-08T22:20:05+00:00
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