By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be either United States citizens or
By Caroline D. Ciraolo Journal of Tax Practice and Procedure Spring 2020 Edition At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward. “We cannot continue to operate
By Christopher M. Ferguson NYSSCPA Tax Stringer April 1, 2020 On Sep. 28, 2018, the IRS’s Offshore Voluntary Disclosure Program (OVDP) came to an end; however, offshore tax and reporting noncompliance persists in today’s increasingly global economy. Tax advisors are still helping clients who have been—or continue to be—noncompliant with their
By Sharon L. McCarthy The CPA Journal March 2020 Edition Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The former CPA is now a
By Usman Mohammad The CPA Journal February 2020 Edition Foreign asset reporting—including the reporting of foreign retirement plans—is a high priority for the IRS, which in 2019 listed the “failure to report offshore funds” as one of its “Dirty Dozen Tax Scams,” and has done so for several years running. Individuals
By: Michael Sardar Tax Stringer April 2019 Edition Download Publication On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners were anxious for the IRS
By: Bryan C. Skarlatos and Stephen A. Josey Journal of Tax Practice & Procedure February – March 2019 Edition Tax law is so complicated that nearly everyone makes a mistake sooner or later. What should a taxpayer do when he or she learns of a mistake on a previously filed tax return? Of
By: Usman Mohammad The CPA Journal January 2019 Edition On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (https://bit.ly/2UHHdLm). The memo sets forth the IRS’s current policy for handling voluntary disclosures (both offshore and domestic) following the closing of the IRS’s
By: Bryan C. Skarlatos & Michael Sardar June – July 2018 Edition Journal of Tax Practice & Procedure Imagine a situation in which Congress passed a statute establishing civil penalties for certain conduct, including the maximum penalty that may be imposed for such conduct, and delegated enforcement of the statute to a federal
By Wilda Lin The CPA Journal October 2018 Edition Reports of Foreign Financial and Bank Accounts (FBAR) have gained prominence since the Department of Justice began investigating the accounts of Swiss banks, starting with UBS almost a decade ago. Who must file FBARs? Many people who own foreign accounts hail
