One reason why tax compliance so challenging is that the federal tax code is always a moving target. The challenge isn’t only that the code is so complicated. It is that every year there is uncertainty about what Congress will include in it. One aspect of this is a set […]
In part one of this post, we introduced the subject of bankruptcy and tax debt. We used a Texas case to illustrate the point that a bankruptcy filing does not necessarily stop the IRS from trying to collect back taxes from you. In this part of the post, let’s look […]
The Fifth Amendment protects an individual from being forced to incriminate himself or herself, often referred to as “pleading the fifth.” In the past, some have unsuccessfully attempted to assert the Fifth Amendment as a reason to avoid filing tax returns, or to file tax returns that don’t report any […]
The Department of Justice announced the conviction of an Alaskan doctor who used secret accounts in Costa Rica to hide assets from his wife, as well as to evade U.S. taxes. At his sentencing next March, he faces a maximum of 20 years imprisonment. He could also be forced to […]
Bankruptcy is by no means a sure-fire way to evade the IRS. An octogenarian widow of a Texas billionaire is finding this out now. In this post, we will discuss the case of Caroline “Dee” Wyly, against whom the Internal Revenue Agency is seeking a $386 million tax fraud penalty. […]
The word “trust” has a lot packed into it. Broadly, of course, it refers to belief or confidence in the reliability or faithfulness of a person or an organization. But in legal terms, a trust is a legal mechanism by which certain property rights are held by one party to […]
The IRS continues to struggle with budget cuts, but it is far from toothless. In fact, the agency recently began using nasty new tools that can track cell phone location data by mimicking cell towers. These tools are called “stringrays” or cell-site simulators. Last week, the IRS commissioner went before […]
Tax law is filled with abbreviations. IRS of course stands for Internal Revenue Service. OIC stands for offer in compromise. FBAR stands for Report of Foreign Bank and Financial Accounts (now also known as FinCEN form 114) and so on. The newest abbreviation is CRS. (No, not CVS, the national […]
The Internal Revenue Service has released a draft version of the form that will be used by foreign financial institutions (FFIs) to report information about U.S. accounts under the terms of the Foreign Account Tax Compliance Act (FATCA). Passed into law in 2010, FATCA requires foreign financial institutions to report […]
The IRS has added four more foreign financial institutions to its list of “Foreign Financial Institutions or Facilitators.” Those who had accounts at one or more of these institutions are required to pay an increased penalty of 50% if they wish to participate in the Offshore Voluntary Disclosure Program (OVDP). […]