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Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification | Holland & Knight LLP

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP).

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Foreign Account Quiet Disclosures are Dangerous (Case Study)

When a US person learns they are out of compliance for not properly reporting their foreign accounts and assets to the US government, Google may lead…

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Streamlined Compliance Procedures (Common Filing FAQs)

Chances are that if you are a US Person Taxpayer and out of compliance for not properly reporting foreign accounts, assets, investments, and income…

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International Taxpayer s Resource Guide for Offshore Compliance

When dealing with individuals for US tax, one of the key important factors in determining whether that person qualifies as a resident of the United…

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Delinquent & Unfiled Tax Returns with Undisclosed Offshore Income

When a US Taxpayer has not filed tax returns in one or more prior years, they are at risk for IRS fines and penalties. When there are unfiled tax…

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