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On October 26, 2017, the IRS sent a clear signal that OVDP changes are coming soon. The signal that the 2018 OVDP changes are imminent came from Mr. Daniel Price, an attorney with the IRS Office of Chief Counsel, Small Business/Self-Employed Division, who participated in a panel discussion of offshore accounts and compliance at the […]
2018 FBAR audits are set to increase at a dramatic pace. In this article, I would like to discuss what the FBAR audits are and why 2017-2018 will be the period of time when we believe that the FBAR audits will gain as a percentage of the overall IRS audits compared to earlier years. 2018 […]
One of the most common questions that US taxpayers have is regarding FBAR Safe Deposit Box reporting requirements. While the general answer is clear, there may be complications in certain cases. General FBAR Safe Deposit Box Reporting Requirements In general, a safe deposit box is not considered to be a financial account and, therefore, not […]
On October 9, 2017, the Lebanese Parliament passed for the second time a controversial tax bill which may increase several Lebanese taxes. The passage of this increase in Lebanese taxes comes after a turbulent legislative history and it is not yet certain that it will actually become the law and survive a Constitutional challenge. History […]
After the implementation of FATCA in 2014, Sherayzen Law Office made a prediction that there would be a major increase in FBAR litigation a few years later once the IRS is able to process data obtained through FATCA and the Swiss Bank Program. This prediction is now becoming a reality as the US Department of […]