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The Statute of Limitations may not be very limiting

If you fail to include your foreign assets the statute of limitations for the IRS to audit your tax returns may be longer than your expected Jeffrey S. Freeman, J.D., LL.M The Department of Justice...

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Did you win big? Uncle Sam wants his share

Big or small, each prize earning is fully taxable Jeffrey S. Freeman, J.D., LL.M Between NBA Playoffs and the Kentucky Derby, May might have been the lucky month for your pocketbook. Nearly 165,000...

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Understanding the IRS Compliance Programs

Answering your frequently asked questions about the offshore voluntary disclosure programs and streamlined compliance procedures Jeffrey S. Freeman, J.D., LL.M The IRS  is hoping to provide greater...

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It’s a Puzzle: Filing Offshore Account Taxes

Filing taxes on your offshore accounts is a complicated puzzle, but start with the right pieces and you can be successful Jeffrey S. Freeman, J.D., LL.M Offshore accounts have received a lot of...

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You’ve Got Options: Should you use the OVDP?

The Offshore Voluntary Disclosure Program is not the only way to come into compliance, opting out of the program may be a better fit Jeffrey S. Freeman, J.D., LL.M The IRS has released changed to its...

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Streamlined Penalties – a good thing!

Knowing the penalty structure for the newly modified IRS programs can make choosing your best option even easier. Jeffrey S. Freeman, J.D., LL.M Changes to the Offshore Voluntary Disclosure Program...

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IRS Compliance Programs and Understanding Them

The IRS is hoping to provide greater flexibility to appeal to a greater audience if taxpayers that have been waiting to come into compliance with their taxes. Previous programs have allowed 45,000...

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Using The OVDP: What Are Your Options?

The IRS has released changed to its Offshore Voluntary Disclosure Program (OVDP) encouraging a broader group of U.S. taxpayers to come into compliance. The streamlined procedures allow for those who...

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Easing the FATCA Compliance Burden

New IRS guidance seeks to reduce the compliance burden for intermediated payments Jeffrey S. Freeman, J.D., LL.M Foreign Account Tax Compliance Act (FATCA) has been seen by many institutions as a...

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FATCA Implemented, but not strong

FATCA has been implemented, but it is not strong many groups still harboring strong political and legal animosity. FATCA is now legally in force, but the Treasury department is promising “to go easy”...

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You forgot to file FBARs and Pay Taxes on your foreign financial accounts . ....

Part 1: Consider the Offshore Voluntary Disclosure Program If you have foreign accounts and fail to properly file your taxes with the Internal Revenue Service (IRS) there are big consequences. Failure...

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FATCA Implemented, But Not Strong

FATCA has been implemented, but it is not strong many groups still harboring strong political and legal animosity. FATCA is now legally in force, but the Treasury department is promising “to go easy”...

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Ignorance and The IRS Don’t Mix

Whenever you play Monopoly you eagerly await the Get out of Jail free card so your stay can be brief and painless. The IRS doesn’t play by the Boardwalk or Park Place rules. Ignorance to the tax laws...

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Serve Your Clients First FATCA Last

Step back from all the changes your financial institution has undertaken in the past year – Did you do the changes to increase customer satisfaction or to make the IRS happy? Chances are your...

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The IRS Taxes All Income, Legal or Not

Is there a difference between trading tickets with a friend for a stay at their vacation home and scalping tickets for a big game? One you might see as a legal trade and the other as obviously illegal....

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Serve Your Clients First, then FATCA

Don’t ruin your customer relationship to meet FATCA requirements Jeffrey S. Freeman, J.D., LL.M Step back from all the changes your financial institution has undertaken in the past year – Did you do...

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Two Forms to File Foreign Assets

Similar, but both Form 8938 and FBAR Form 114 may be necessary At first glance Form 8938, Statement of Specified Foreign Financial Assets, and FBAR (Foreign Bank Account) FinCEN Form 114 appear very...

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You forgot to file FBARs and pay U.S. tax on your foreign financial accounts....

You are trying to correct your wrongs, but what if it was just an honest mistake? In Part One we looked at the harsh civil and criminal penalties that you are open to by not filing FBARs on your...

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Ignorance Could Mean “Willful” With the IRS

“I didn’t know” won’t get you very far with the IRS during an audit, especially when you have undisclosed foreign financial accounts…. Jeffrey S. Freeman, J.D., LL.M Whenever you play Monopoly you...

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Citizens leave, Companies Invert

Taxes seem to be motivating citizens and companies alike to look for foreign homes Jeffrey S. Freeman, J.D., LL.M FATCA has caused shake ups worldwide among financial institutions and foreign account...

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