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Paradoxically, one of the obstacles currently facing U.S. taxpayers who wish to file their delinquent FBARs and conduct a voluntary disclosure of their foreign assets are their own accountants – more precisely, the inability of many accountants to understand that FBAR disclosure is a legal matter to a much greater extent than an accounting matter. […]
Are you planning on starting a partnership for business purposes? Usually, partnerships will incur various costs while forming a partnership. Some of these costs may be deductible or amortizable, others will not. This article will examine the deductibility of the most common costs in the formation of a partnership. Partnerships often involve complex legal and […]
On March 1, 2013, the IRS announced that the underpayment and overpayment interest rates will remain the same for the calendar quarter beginning April 1, 2013. The rates will be: three (3) percent for overpayments [two (2) percent in the case of a corporation]; three (3) percent for underpayments; five (5) percent for large corporate […]
In another essay, I previously discussed the possible inclusion of the business ownership interests in the calculation of the OVDP (2012 Offshore Voluntary Disclosure Program) Offshore Penalty. In this article, I would like to explore in more depth the application of the Offshore Penalty to ownership of business interests. OVDP Offshore Penalty It is a […]
The taxpayers who enter into the IRS Offshore Voluntary Disclosure Program (“OVDP”) often have failed to file an FBAR to report an account over which the taxpayer has signature authority. The question arises about whether such accounts should be included in the calculation of the OVDP Offshore Penalty? The answer to this question is – […]