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The IRS has announced it will begin to shut down the 2014 Offshore Voluntary Disclosure Program (OVDP). The program will close on September 28, 2018. Therefore, U.S. taxpayers with undisclosed foreign financial assets have a limited amount of time to use the OVDP before the program ends. Background More than 56,000 taxpayers have used one […]

As part of our tax and estate planning practice in Connecticut and New York we do a lot of planning and estate administration.  Part of the estate documents we and many other planners put together include terminology regarding “Portability”.  In 2010, Congress introduced into the tax code with Internal Revenue Code (I.R.C.) § 2010(c)(2) the […]

Yesterday three senators introduced legislation that would repeal the IRS’s use of private debt collectors. On December 4, 2015, President Obama signed the Fixing America’s Surface Transportation (FAST) Act (Pub. L. No. 114-94) into law—the first federal law in over a decade to provide long-term funding certainty for surface transportation infrastructure planning and investment.  In addition […]

Delinquent taxpayers may soon face major roadblocks when attempting to travel.  Internal Revenue Code § 7345 requires the IRS to notify the State Department when an individual has a “serious delinquent” tax liability.  The State Department, in turn, will generally deny an application for a new or renewed passport after receiving such a certification.  The State […]

An individual’s petition to invalidate four Notices of Federal Tax Liens filed against him was dismissed for failure to state a claim on which relief could be granted. He petitioned the court to invalidate the liens based on a number of tax-protestor-type arguments including, inter alia, that there was no authority for filing the Notices […]

The focus of our practice is on civil and criminal tax controversy, and we are often asked to defend taxpayers under IRS examination. One of the areas focused on by the IRS are the expenses claimed by taxpayers against their income. Taxpayers need to understand that they have to carry the burden of showing they […]

A New York City man pleaded guilty today to a criminal information charging him with tax evasion for tax years 2003 through 2005 and 2007 through 2010, announced Principal Deputy Assistant Attorney General Caroline D. Ciraolo, head of the Justice Department’s Tax Division, and U.S. Attorney Robert L. Capers of the Eastern District of New […]

If you have a foreign bank account, especially in Switzerland or Israel, coming forward quickly is probably in your best interest. The Israeli Finance Ministry announced that the United States and Israel have concluded the text of an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by the US […]

The focus of our practice is civil and criminal taxpayer representation, and we have represented many taxpayer’s involved with foreign bank accounts. The increased focus on international tax enforcement by both the IRS and the Department of Justice comes as no surprise.  However, the speed at which the United States Government has been able to improve its relationship and obtain information regarding foreign bank accounts held by US taxpayers from […]

Attorney Eric Green will be a panelist on a national teleconference for the American Bar Association Tax Section on July 12, 2012 entitled “Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues.”  The panel will review issues that arise during IRS civil audits of closely held businesses in which […]