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Although experienced practitioners knew the IRS position, it was formally …

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Vic Abajian appeared as a panelist and speaker at the 2015 California Tax Practitioners’ Conference presented by the Los Angeles County Bar Association’s Taxation Section. The conference regularly attracts California’s most powerful and respected tax professionals for a day of continuing educational seminars and interactive dialogue about the latest trending tax topics in the taxation […]

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Offer In Compromise TIP – Equity in income producing assets will generally not be included in the reasonable collection potential of a viable, ongoing business. We see many offer in compromise analyses that mistakenly include the equity in business assets and thus, taxpayers may end up paying a much higher offer amount or worse, not […]

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The 5% penalty Streamlined Filing Procedures for undisclosed foreign bank accounts and assets was modified and is now available for domestic taxpayers with foreign accounts. It’s available only to taxpayers who’s failure to file an FBAR was due to non-willful conduct. For willful conduct, a taxpayer would be better advised to join the OVDP whichThe […]

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A major change in the way taxpayers could disclose foreign bank accounts happened in June of 2014 when the IRS implemented changes to its OVDP and streamlined reporting programs. Among the changes made to the OVDP is an increase in the miscellaneous offshore penalty from 27.5% to 50% where the individual had an account at […]

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Former top Swiss banking executive Raoul Weil was acquitted of charges that he helped wealthy American client hide their $20 billion in secret accounts. The jury deliberated for just 90 minutes before reaching their verdict. Charges for conspiring to defraud the U.S. government include five years in prison and $250,000 in fines. While Raoul Weil’s […]

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Also Referred to as the 2014 OVDP. The 2014 OVDP is a continuation of the 2012 OVDP but for a few changes.  This article attempts to highlight the changes and discuss why they are significant.  The changes are as follows: Increased 50% Penalty A 50% offshore penalty applies if either a foreign financial institution at […]

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Following an extensive investigation by the United States Justice Department, Swiss banking giant Credit Suisse pleaded guilty on Monday to aiding U.S. clients evade taxes. Eric Holder, U.S. Attorney General stated that the bank was involved in an “extensive and wide-ranging conspiracy” to help U.S. taxpayers avoid tax liabilities on their offshore income. He added […]

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The IRS’ (Internal Revenue Service) Criminal Investigation (CI) division issues informative reports for every fiscal year in order to highlight its main areas of focus. There were some important issues highlighted in the report for fiscal year 2013 published earlier this year in February. There was a 12.5% increase from 2012 in criminal investigations completed […]

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Credit Suisse testifies before Senate about secret Swiss bank accounts and plans to provide more names to IRS. As the United States Department of Justice closes in on its search through FATCA for US taxpayers who hid their funds to avoid tax liability, several international banks and their employees have been charged with aiding these […]

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