Entries by Manager

Mistake as Reasonable Cause | Offshore Voluntary Disclosure Lawyer

This article is a continuation of a series of articles on the Reasonable Cause Exception as a defense against various IRS penalties. Today, we will be exploring whether a mistake made by a taxpayer satisfies the ordinary business care and prudence standard and can be considered a reasonable cause. Mistake Alone Does Not Constitute Reasonable […]

Ordinary Business Care and Prudence Standard | International Tax Lawyer

Ordinary Business Care and Prudence Standard is a requirement that is present, explicitly or implicitly, in all reasonable cause defenses. In this article, I would like to explain what Ordinary Business Care and Prudence Standard means and what are the main factors for analyzing whether a taxpayer met the burden of proof required under the […]

Streamlined Disclosure Attorney Madison | FATCA OVDP Lawyer

In today’s world connected through an invisible network of new technologies, a great number of persons prefer to choose an attorney based on his qualities rather than his state of residence. The residents of Madison, Wisconsin, similarly search for such an attorney, especially in the area of Streamlined compliance procedures by utilizing the search words: […]

International Business Transactions | Business Tax Lawyer Minneapolis

Despite their apparent diversity and complexity, international business transactions can be grouped into three categories: export of goods and services, licensing and technology transfer and foreign investment transactions. International Business Transactions: Export of Goods and Services The first category of international business transactions consists of exports involving a sale of a commodity, manufactured goods or […]