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The IRS Private Letter Rulings (“PLR”) and the IRS Technical Advice Memoranda (“TAM”) often get confused by non-practitioners. In this small essay, I will engage in a brief PLR TAM comparison in order to clarify the similarities and differences between both types of IRS administrative guidance. PLR TAM Comparison: Similarities Let’s begin our PLR TAM […]
On April 4, 2019, the IRS issued the FBAR Fact Sheet in order to acquaint US taxpayers with this highly important reporting requirement for foreign accounts held by US persons. Let’s analyze the new fact sheet in more detail. FBAR Fact Sheet: Organizational Structure of the Fact Sheet The IRS FBAR Fact Sheet can be […]
An analysis of the fiscal year 2018 DOJ criminal case statistics reveals certain interesting patterns about federal criminal tax prosecution in that year. Let’s explore in more detail these patterns. 2018 DOJ Criminal Case Statistics: Typical Tax Criminal The analysis of the FY 2018 DOJ criminal case statistics reveals an interesting fact – a typical […]
On June 7, 2019, the Organization for Economic Cooperation and Development (“OECD”) announced that countries shared information concerning 47 million financial accounts under the OECD’s Common Reporting Standard (“CRS”). Let’s explore this CRS success in more detail. Measuring CRS Success: What is CRS? CRS can be called the response of the rest of the world […]
US taxpayers who own Hungarian bank accounts may have to comply with a large number of US tax reporting requirements. In particular, they need to be concerned about reporting income generated by their Hungarian bank accounts as well as disclosing the ownership of these accounts on FBAR and Form 8938. Other requirements may apply, but […]