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On March 15, 2019, the IRS announced that it will keep undisclosed offshore bank accounts on its 2019 Dirty Dozen list. 2019 Dirty Dozen List: Background Information The “Dirty Dozen” list is complied annually by the IRS. It consists of common tax scams and noncompliance schemes that the IRS prioritizes in its enforcement efforts. Many […]
With this article, we begin a series of articles dedicated to the description of the IRS compliance campaigns initiated between March of 2018 and April of 2019. This article is dedicated to the March 2018 IRS Compliance Campaigns. March 2018 IRS Compliance Campaigns: Background Information On March 13, 2018, the IRS Large Business and International […]
Oftentimes, as part of their noncompetition agreement, a taxpayer may receive income for restraining from competing with another party in certain areas. An issue often arises with respect to international noncompetition agreement income sourcing rules – i.e. should the income paid as part of such a noncompetition agreement be considered US-source income or foreign-source income? […]
Failure to file FBARs for secret Russian bank accounts and income tax evasion led to the imposition of a five-year prison sentence on a New Jersey chiropractor. This is the essence of the new IRS victory in the Amato case. Let’s explore this case in more detail, because the case demonstrates the long reach of […]
The Czech Republic just joined an ever increasing list of countries who are introducing their own versions of the digital tax. Let’s explore this development in more detail. Czech Digital Tax Proposal: Overview The Czech Republic’s ministry of finance just announced that it will introduce by the end of May of this year a 7% […]