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IRS Wins Another 50% Willful FBAR Penalty Case!

 A district court has found in Agrawal, (DC WI 12/9/2019) 124 AFTR 2d ¶2019-5522 that a taxpayer was liable for nonwillful FBAR penalties and that the reasonable cause exception did not apply because the taxpayer did not act with ordinary business care and prudence when he prepared some of his own returns and when he had an…
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IRS Collection Activity Expected to Increase in 2020!

Hear that noise? It’s the collective sighs of tax professionals around the country upon learning that the Internal Revenue Service (IRS) is in the midst of a hiring spree. In FY 2019, the IRS employed about 78,004 employees, including more than 12,600 temporary and seasonal staff. According to IRS Commissioner Charles Rettig, the IRS is…
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Comm'r Warns Taxpayers – Streamlined Offshore Procedures Won't Last Forever!

Last week I attended the ABA's 36th National Institute on Criminal Tax Fraud in Las Vegas, where IRS Commissioner Charles "Chuck" Rettig announced that for those taxpayers who still have income from unreported offshore accounts, they should take note that the Streamlined Offshore Procedures Won't Last Forever.  Taxpayers should remember that the OVDP (f/k/a OVDI) started…
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Ten Facts About Tax Expatriation – Part III

As we previously discussed in Ten Facts About Tax Expatriation - Part I & Part II, whatever your motives, just because you leave the United States and renounce your citizenship, don't assume you can leave U.S. taxes (or U.S. tax forms and complexity) behind, particularly if you are financially well-off and there are 10 things you need…
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