by Igor Drabkin | Mar 6, 2020 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
Giving up your U.S. citizenship is considered a taxable event, i.e. the IRS treats the date of the renunciation (or technically, the date before the renunciation) of the citizenship as a date of the virtual sale of the assets at a market price.
by Igor Drabkin | Mar 15, 2019 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.
by David Holtz | Mar 5, 2019 | Criminal Tax, Employment Tax, Internal Revenue Service, Tax Collection
If You Owe Employment Taxes and You Cannot Fully Pay, You Need a Tax Attorney. Period! The Criminal Division of the Internal Revenue Service in Los Angeles has recently changed its policy regarding whether the failure to collect and pay employee withheld employment... 
by David Holtz | Feb 25, 2019 | Audit, Criminal Tax, Employment Tax, Internal Revenue Service, Tax Collection, Tax Litigation
If You Owe Over $100,000 in Federal Employment Taxes and You Cannot Fully Pay – You need an Attorney. Period! The IRS New Policy is Wrongfully Creating a Debtors’ Prison for Employment Taxes Debts. The Criminal Division of the Internal Revenue Service in Los... 
by Igor Drabkin | Dec 2, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
On November 20, 2018, the IRS issued a Memorandum, describing the process for all voluntary disclosures following the closing of the 2014 OVDP on September 28, 2018. The new procedures are effective for all disclosures after September 28, 2018. Under the new procedures, the taxpayers with hidden foreign bank accounts, whose behavior may be considered willful, will find stricter requirements and higher penalties.
by David J. Warner | Nov 13, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
In general, the United States has five years to start criminal proceedings in a criminal case (either through an indictment or information). 18 U.S.C. § 3282. However, there are several statutes that could suspend or extend this five-year period, and an individual might not even know if the statute of limitations has been extended.
