| 
On November 3, 2017, the IRS Large Business and International Division (“LB&I”) announced the rollout of additional 11 IRS Compliance Campaigns in addition to the 13 already existing campaigns. Most of these campaigns directly address the IRS concerns with respect to US international tax law compliance. Let’s explore these new 11 IRS Compliance Campaigns. New […]
Sale of Russian Real Estate by US permanent residents was the subject of a recent guidance letter from the Russian Ministry of Finance (“MOF”). Guidance Letter 03-04-05/66382 (dated October 11, 2011, but released only earlier this week) provides a thorough analysis of questions concerning the sale of real estate in Russia by a US resident […]
On October 26, 2017, the IRS sent a clear signal that OVDP changes are coming soon. The signal that the 2018 OVDP changes are imminent came from Mr. Daniel Price, an attorney with the IRS Office of Chief Counsel, Small Business/Self-Employed Division, who participated in a panel discussion of offshore accounts and compliance at the […]
2018 FBAR audits are set to increase at a dramatic pace. In this article, I would like to discuss what the FBAR audits are and why 2017-2018 will be the period of time when we believe that the FBAR audits will gain as a percentage of the overall IRS audits compared to earlier years. 2018 […]
One of the most common questions that US taxpayers have is regarding FBAR Safe Deposit Box reporting requirements. While the general answer is clear, there may be complications in certain cases. General FBAR Safe Deposit Box Reporting Requirements In general, a safe deposit box is not considered to be a financial account and, therefore, not […]