Entries by Manager

SFOP Non-Residency | Streamlined Foreign Offshore Procedures Lawyer

February 5, 2019 in , /by

Streamlined Foreign Offshore Procedures (“SFOP”) is currently the preferred offshore voluntary disclosure option for US taxpayers who reside overseas, recently came to the United States or recently left the United States. Hence, the issue of SFOP eligibility (i.e. the ability of a taxpayer to participate in this program) is very important for these taxpayers. Today, […]

FinCEN Form 114 Filers | FBAR Tax Lawyer & Attorney Minnesota Minneapolis

February 4, 2019 in , /by

The Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (a/k/a FBAR) is arguably the most important information return concerning foreign accounts. Its importance stems first and foremost from the extremely severe Form 114 penalties, which range from criminal penalties of up to 10 years in prison to willful and even non-willful penalties that […]

2019 Offshore Voluntary Disclosure Options | International Tax Lawyers

February 4, 2019 in , /by

The closure of the IRS flagship 2014 Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018 posed a critical issue of the 2019 offshore voluntary disclosure options available to US taxpayers. This is precisely the issue that I would like to explore today – the 2019 offshore voluntary disclosure options available to US taxpayers who […]