Skip links

Tag: International Tax Controversies

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining

Complying With U.S. Requirements For Foreign Pension Plans

By Cassandra Vogel The CPA Journal November 2016 Edition The migration of workers into and out of the United States is a fact of the modern interconnected world. Consequently, many U.S. taxpayers acquire an interest in a foreign pension plan or other deferred compensation arrangement during time spent working abroad. Because

The United States Strikes Again – The New Swiss Bank Program

By Caroline D. Ciraolo Financier Worldwide November 2013 THE UNITED STATES STRIKES AGAIN – THE NEW SWISS BANK PROGRAM The United States has taken another giant leap forward in its aggressive pursuit of individuals and entities who attempt to evade, or help others evade, US tax reporting and payment obligations

Sergio Garcia In Victory Over The IRS

By Robert S. Fink and Wilda Lin Journal of Tax Practice & Procedure June – July 2013 Edition Robert S. Fink and Wilda Lin examine the IRS Issue Management Team’s International Individual Compliance (IIC) Group. The purpose of the IIC is to scrutinize foreign athletes and entertainers to ensure that they have