Entries by Manager

Outbound Foreign Trust: An Introduction

One of the most fundamental distinctions in US foreign trust law is the difference between an inbound foreign trust and an outbound foreign trust. This distinction was emphasized by the landmark piece of legislation “The Small Business Job Protection Act of 1996″ and should be clearly understood by US tax lawyers as well as US […]

Streamlined Five Percent Offshore Penalty Calculation

Despite its appearances, the calculation of the Streamlined Domestic Offshore Procedures Title 26 Miscellaneous Offshore Penalty (“Streamlined Five Percent Offshore Penalty) may actually be a complex process. Moreover, the correct calculation of the Streamlined Five Percent Offshore Penalty may lead to some paradoxical conclusions, including a preference for the OVDP Penalty (now closed). Due to […]

Austin FBAR Tax Lawyer

A question that I would like to explore in this article is: Who is considered to be an Austin FBAR tax lawyer? It seems to be an odd question, because a lot of people would say that an Austin FBAR tax lawyer is an attorney who resides in Austin and does FBAR law. This, however, […]