Payroll management is one of the most complicated aspects of running a business. In particular, withholding, accounting for and paying employment taxes is an extremely arduous task. Brown, PC represents some of the biggest global corporations that often have multiple brands and complicated business structures with millions of dollars in […]
Taxes present the balancing act of reducing liability within the bounds of IRS regulations. This equation becomes more difficult for individuals and corporations with high value assets or complex business structures. Unfortunately, higher income people and companies are generally on law enforcement radar and most likely to be targeted for […]
Texas Tax Evasion Attorney for Audits, Investigations and Criminal Cases While Texas does not have an individual income tax, individuals and businesses in the state may still owe various taxes to the Texas Comptroller and the Internal Revenue Service (IRS). The Texas Comptroller and IRS vigorously enforce taxpayers’ obligations, and […]
The marketplace and the court of public opinion do not wait for case resolution or jury verdict. Negative publicity, rumors and speculation surrounding a tax dispute or white-collar investigation can destroy brand equity or reputation in a matter of weeks, even days, while it could take years to resolve the […]
A Team Approach To Resolve Offshore Account Issues Our founder, Lawrence Brown, believes that a team approach creates the highest likelihood of achieving the most favorable results possible for clients in offshore account compliance, digital currency and OVDP cases. Since the inception of the 2009 Offshore Voluntary Disclosure Program, offshore […]
Despite the ongoing frenzy of publicity threatening criminal prosecution against U.S. taxpayers with foreign accounts, it is not illegal for U.S. taxpayers to maintain financial accounts at foreign financial institutions. However, U.S. taxpayers with foreign assets must fulfill various reporting requirements under the Bank Secrecy Act and the Internal Revenue […]
In response to the high number of participants in the 2009 and 2011 Offshore Voluntary Disclosure Programs, the IRS created a third program, which opened up for submissions on January 9, 2012. However, with pending changes resulting from Foreign Account Tax Compliance Act (FATCA) agreements signed by various foreign governments this year, […]
To encourage taxpayer participation in the Offshore Voluntary Disclosure Program, the IRS has implemented attractive taxpayer incentives. One of the primary benefits of participating in and completing the OVDP is that, once a closing agreement is reached, criminal prosecution for the issues addressed within the disclosure is no longer a […]
Once a taxpayer has submitted all of the required disclosure materials and the IRS has issued a Form 906, Closing Agreement, the taxpayer is faced with an important decision: sign the agreement and pay the 27.5% or 50% miscellaneous OVDP penalty, or opt-out of the civil penalty structure of the program and […]
Taxpayers who have already initiated the Offshore Voluntary Disclosure process under previous programs may still be eligible for the reduced penalty structure offered by the New Streamlined Offshore Programs . If your OVDP letter and attachments were submitted to the IRS prior to July 1, 2014, and you have not yet executed […]