March 2, 2019Termination of OVDP and way forward Following the termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018,…
February 17, 2019Introduction Expatriates (Expats) who continue to ignore their obligations to file U.S. Federal Income Tax returns and who fail to…
February 11, 2019The Trust Fund Recovery Penalty: Are You At Risk? Introduction The assessment of the § 6672 penalty can be devastating,…
February 1, 2019Wilfull FBAR Penalty. The following is intended as an update to my January 26, 2019 Blog on the subject of…
January 31, 2019Offshore disclosure to IRS. The key to making an offshore disclosure to the IRS using either the Domestic or Foreign…
January 26, 2019Assessment of FBAR penalty Some practitioners have applauded the decision in United States v. Colliot, 2018 U.S. Dist. LEXIS 83159…
May 15, 2018If you are self-employed and recently received an examination notice from the Internal Revenue Service or are have concerns about…
May 3, 2018Serial Tax Return Non-filers. Every year, thousands of individuals fail to file their Federal and State Income Tax returns despite…
May 3, 2018Global Tax Initiatives and Kenya. Kenya Revenue Authority (KRA) has thrown down the gauntlet, advising Kenyans who are working overseas…
April 10, 2018Case Facts. April 3, 2018, the U.S. District Court in United States v. Garrity held that, for purposes of the…
