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David J. Warner to Speak at the USC Gould School of Law 2019 Tax Institute

David J. Warner to Speak at the USC Gould School of Law 2019 Tax Institute

by David J. Warner | Jan 25, 2019 | FBAR, Firm News, Internal Revenue Service

Holtz, Slavett & Drabkin tax attorney, David J. Warner, will be a speaker at the USC Gould School of Law 2019 Tax Institute, which will be held in Los Angeles on January 28-30, 2019. David will be a speaker on the panel, “Contesting and Litigating International...
Tax Practitioner Alert: The IRS Is Assessing Excessive Foreign Bank Account Report (FBAR) Penalties

Tax Practitioner Alert: The IRS Is Assessing Excessive Foreign Bank Account Report (FBAR) Penalties

by David J. Warner | Jan 18, 2019 | FBAR

Certain individuals and entities are required to file a FinCEN Form 114, Report of Foreign Bank Account Report (commonly called an “FBAR”), if they have a financial interest or signature authority in a foreign bank account. The FBAR form is filed electronically on the...
Tax Professionals Be Aware: The Rules for Claiming a Refund of Foreign Bank Account Report (FBAR) Penalties May Have Just Changed

Tax Professionals Be Aware: The Rules for Claiming a Refund of Foreign Bank Account Report (FBAR) Penalties May Have Just Changed

by David J. Warner | Jan 18, 2019 | FBAR

Certain individuals and entities are required to file a FinCEN Form 114, Report of Foreign Bank Account Report (commonly called an “FBAR”), if they have a financial interest or signature authority in a foreign bank account. The FBAR form is filed electronically on the...
Taxpayers Can Still Make Voluntary Disclosures for Offshore Accounts

Taxpayers Can Still Make Voluntary Disclosures for Offshore Accounts

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.

Think the Criminal Statute of Limitations for Failure to Report Foreign Bank Accounts Has Expired? Think Again.

Think the Criminal Statute of Limitations for Failure to Report Foreign Bank Accounts Has Expired? Think Again.

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.

Tax Crime Does Not Pay — Says Department of Justice

Tax Crime Does Not Pay — Says Department of Justice

by Igor Drabkin | Apr 11, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Tax Crime Does Not Pay — Says Department of Justice

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Holtz, Slavett & Drabkin
Former IRS Tax Attorneys
(310) 550-6200
10940 Wilshire Boulevard
Suite 2000
Los Angeles, CA 90024

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  • IRS Cracking Down on Section 1202 Qualified Small Business Stock (QSBS) Claims
  • Six Holtz, Slavett & Drabkin Attorneys Named in 2025 Southern California Super Lawyers List
  • Michele Weiss to Present on Passthroughs Hot Topics at the Upcoming ABA Mid-Year Conference
  • IRS Issues Notice Providing Relief to California Wildfire Victims
Internal Revenue Service > FBAR

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Suite 2000
Los Angeles, CA 90024
Phone: (310) 550-6200
Fax: (310) 774-3904

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Newport Beach, CA 92660
Phone: (949) 999-6606
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Recent Blog Posts

  • Michele Weiss Selected for Lawdragon 500 Leading Tax Lawyers Guide
  • IRS Cracking Down on Section 1202 Qualified Small Business Stock (QSBS) Claims
  • Six Holtz, Slavett & Drabkin Attorneys Named in 2025 Southern California Super Lawyers List
  • Michele Weiss to Present on Passthroughs Hot Topics at the Upcoming ABA Mid-Year Conference
  • IRS Issues Notice Providing Relief to California Wildfire Victims
  • IRS is Allowed to Serve John Doe Summons on a “Gig Economy” Platform
  • Holtz, Slavett & Drabkin to Sponsor 2024 Criminal Tax Fraud and Tax Controversy Conference in Las Vegas

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