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Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties

Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties

by Igor Drabkin | Aug 31, 2020 | Audit, FBAR, Internal Revenue Service, Offshore Income, Tax Litigation, Uncategorized

IRS implements new COVID-19 Initiative to Assist Taxpayers

IRS implements new COVID-19 Initiative to Assist Taxpayers

by Gary Slavett | Mar 25, 2020 | Audit, COVID-19, Criminal Tax, Employment Tax, Exempt Organizations, FBAR, Innocent Spouse Relief, Internal Revenue Service, Offshore Income, Tax Collection, Tax Litigation, Trust Fund Recovery Penalty

IRS temporarily adjusts and suspends key compliance programs to help people facing the challenges of COVID-19 issues.

Renouncing US Citizenship and US Tax Obligations

Renouncing US Citizenship and US Tax Obligations

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. 

Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.

Israeli Bank Mizrahi-Tefahot Admits to Helping US Taxpayers Conceal Income and Assets; Agrees to Pay $195 Million to U.S.

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.

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 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.

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Holtz, Slavett & Drabkin
Former IRS Tax Attorneys
(310) 550-6200
315 S. Beverly Drive
Suite 515
Beverly Hills, CA 90212

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Recent Posts

  • Pandemic Tax Payment Problems: What should I do if the IRS does not process my check for payment of the my taxes?
  • IRS’s New Micro-Captive Insurance Settlement Program Offers a Path to Resolution, But Is the Settlement Best for You?
  • Igor Drabkin Quoted in Law360 Article
  • Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties
  • Considering Bankruptcy for Your Corporation? This Tax Issue Might Affect Your Business’s Largest Asset
Internal Revenue Service > Offshore Income

Beverly Hills Main Office

315 S. Beverly Drive
Suite 515
Beverly Hills, CA 90212
Phone: (310) 550-6200
Fax: (310) 774-3904

Orange County Office

4695 MacArthur Court
Suite 200
Newport Beach, CA 92660
Phone: (949) 999-6606
Fax: (949) 544-0440

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Suite 1170
Sherman Oaks, CA 91403
Phone: (310) 550-6200
Fax: (310) 774-3904

Recent Posts

  • Pandemic Tax Payment Problems: What should I do if the IRS does not process my check for payment of the my taxes?
  • IRS’s New Micro-Captive Insurance Settlement Program Offers a Path to Resolution, But Is the Settlement Best for You?
  • Igor Drabkin Quoted in Law360 Article
  • Recent FBAR Cases Show Mixed Results in Taxpayers Fighting Against Aggressive Penalties
  • Considering Bankruptcy for Your Corporation? This Tax Issue Might Affect Your Business’s Largest Asset
  • Michele Weiss to present Beverly Hills Bar Association Program on: Managing Tax and Bankruptcy Issues in Your COVID-19 Divorce: Avoid Traps for the Unwary
  • David C. Holtz to Speak at Provisors Tax Masters Affinity Conference Regarding “Strategies for Avoiding Hazards in California Sales and Use Tax Audit”

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