2023-09-26 17:01
By: Anthony N. Verni, Attorney at Law, CPA September 26, 2023 ©2023 THAI RESIDENTS MUST NOW PAY THAI INCOME TAX ON FOREIGN SOURCE INCOME The Thai Revenue Department recently issued Orde… Read More
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Find the latest articles about FBAR, Offhore Tax Reporting and more.
2023-09-26 14:51
By: Anthony N. Verni, Attorney at Law, CPA September 26, 2023 ©2023 LARGE TAX REFUNDS AND THE GHOST PREPARER Earlier this year a Charlotte man was charged with tax fraud in a 20 count c… Read More
2023-09-24 18:15
BY: Anthony N. Verni, Attorney at Law, CPA September 22, 2023 ©2023 FBAR PROSECUTIONS FORMER CFO SENTENCED TO EIGHTY SIX MONTHS IN PRISON On September 21, 2023 a former CFO… Read More
2023-09-19 20:27
By: Anthony N. Verni, Attorney at Law, CPA September 18, 2023 ©2023 WHAT DO OFFERS IN COMPROMISE AND ALUMINUM SIDING HAVE IN COMMON? After many years, I decided to watch Tin Men… Read More
2023-09-08 18:24
By: Anthony N. Verni, Attorney at Law/CPA AUGUST 5, 2023 @ 2023 PROSECUTIONS FOR UNPAID EMPLOYMENT TAXES ON THE RISE ARE YOU AT RISK? The assessment of the § 6672 penalty can be devasta… Read More
2023-09-06 17:19
BY: ANTHONY N. VERNI, ATTORNEY AT LAW, CPA 08/05/2023 ©2023 FBAR PENALTY RELIEF FOR TAXPAYERS SUPREME COURT RULES NON-WILLFUL FBAR PENALTY IS TO BE ASSESSED PER FORM On February… Read More
2023-09-05 19:51
Anthony N. Verni, Attorney at Law, CPA 09/05/2023 © 2023 SUPREME COURT TO DECIDE WHETHER MANDATORY REPATRIATION TAX IS CONSTITUTIONAL WITH RESPECT TO CFC UNDISTRIBUTED INC… Read More
2023-01-18 13:59
Prosecution for employment tax crimes in 2022, reflects an increase in investigations for employment tax violations by the Department of Justice, Tax Division and also provides some i… Read More
FINAL RULE ISSUED UNDER THE CORPORATE TRANSPARENCY ACT – IMPLICATIONS FOR THE SMALL BUSINESS OWNER
2022-11-04 18:54
The U.S. Department of the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently issued its Final Rule under the Corporate Transparency Act (CTA) implementing th… Read More
2022-11-04 18:54
By: Anthony N. Verni, Attorney at Law, Certified Public Accountant November 4, 2022 © 2022 FINAL RULE ISSUED UNDER THE CORPORATE TRANSPARENCY ACT IMPLICATIONS FOR THE SMALL BUSIN… Read More
2022-11-02 15:49
By: Anthony N. Verni, Attorney at Law, Certified Public Accountant November 3, 2022 ©2022 &nbs&hell…Read More
2022-11-01 17:55
By: Anthony N. Verni, Attorney at Law, Certified Public Accountant Date: November 1, 2022 ©2022  &hell…Read More
2022-11-01 14:57
By: Anthony N. Verni, Attorney at Law, Certified Public Accountant Date: October 22, 2022 © &n&hell…Read More
2021-12-01 11:34
The Fifth Circuit recently held in United States v. Bittner, ___ F. 4th ___ (5th Cir. 11/30/21) that the non-willful FBAR penalty should be applied on a per account basis, rather than… Read More
2021-11-20 21:47
NAVIGATING THE FBAR PENALTY MITIGATION GUIDELINES Failure to report your foreign financial accounts on Report of Foreign Bank Account Reports can result in the imposition of steep pen… Read More
2021-11-13 15:13
The issue of whether the Government can repatriate a taxpayer’s foreign assets for purposes of satisfying a taxpayer’s outstanding FBAR penalty judgment has not been extensively… Read More
2021-11-10 20:17
U.S. DISTRICT COURT DECIDES FBAR PENALTY STATUTE OF LIMITATIONS WAIVED AND ASSESMENT OF NON WILLFUL FBAR PENALTIES PER ACCOUNT The U.S. District Court for the Southern Distr… Read More
2021-11-10 20:17
U.S. DISTRICT COURT DECIDES FBAR PENALTY STATUTE OF LIMITATIONS WAIVED AND ASSESMENT OF NON WILLFUL FBAR PENALTIES PER ACCOUNT The U.S. District Court for the Southern District of… Read More
2021-06-05 16:42
The Government will examine efforts by a Taxpayer to avoid detection by the Internal Revenue Service, when deciding whether to assess the Civil Willful FBAR penalty. In particular, the IRS c… Read More
2020-11-16 18:10
The Biden Tax Proposal, if enacted, will have a significant impact on estate planning for those who have failed to take advantage of the current gift and estate tax rules. According to… Read More
2020-08-29 02:22
Why it’s a Very Bad Idea? A taxpayer who owes or anticipates owing a substantial amount of income tax to the IRS may be tempted to transfer his or her property to a spouse, a relative… Read More
2020-08-27 19:54
Duration the IRS Has to Assess Federal Income Tax? The statute of limitation for assessment purposes represents the last day in which the Internal Revenue Service may assess federal income t… Read More
2020-08-22 22:23
Understanding Global Income Tax Systems Understanding how and when the United States imposes federal income tax on its U.S. Tax Residents in cross border transactions has long been a source… Read More
2020-08-08 20:51
IRS Hard at Work Despite the Pandemic Individuals, who have failed to report their foreign financial accounts, may feel a sense of relief, in light of the corona virus and its effects on IRS… Read More
2020-07-08 18:17
Should FBAR non-willful penalty be charged per form or per account? The Courts have recently addressed the issue of whether the FBAR Non-Willful penalty should be assessed per form rather th… Read More
2020-07-08 17:34
Cash intensive businesses Operating a cash intensive business is often accompanied by poor record keeping as well as the lack of any meaningful internal controls. These two factors make it d… Read More
2020-07-04 01:34
Florida man pleads guilty to tax evasion and hiding funds around the world In April 2020, a Florida man pleaded guilty to tax evasion and the willful failure to file FBAR’s. What… Read More
2020-07-02 23:30
Real estate ownership in a Self-Directed Investment Retirement Account (IRA) can provide certain tax benefits to taxpayers who are considering an investment in real estate. However, a… Read More
2020-03-09 18:02
Michael Avenatti’s Indictment The temptation to use unfilled or altered tax returns as well as doctored financial statements for purposes of securing a bank loan, while not common, doe… Read More
2020-03-09 17:01
Effectively Connected Income and it’s Tax Consequences Foreign entities that deliver digital goods and services using the internet as a point of distribution may be subject to U.S. inc… Read More
2019-09-25 23:50
Business Income Deduction for Taxpayer On September 24, 2019, the IRS issued Revenue Procedure 2019-38 now permitting certain taxpayers who hold an interest or interests in… Read More
2019-09-23 16:13
Fraudulent Conveyances in Employment Taxes Employers who willfully fail to remit an employee’s withholding to the IRS are liable to the IRS for the “trust fund recovery penalty&r&hell…Read More
2019-09-20 01:36
Relief Procedures for former U.S. Citizens The new procedures attempt to address problems faced by some U.S. citizens, whose only connection with the United States is that they were born in… Read More
2019-09-13 05:04
Employee versus Independent Contractor Deciding whether to classify an individual as an employee or independent contractor is a decision which requires careful evaluation of many factors and… Read More
2019-09-11 12:55
Data Analytics is the Key During the last decade, the Internal Revenue Service has been limited in its ability to ferret out tax cheats, due, in large part, to a 17% cut in its budget in 201… Read More
2019-09-10 23:58
Citizen Based Taxation The origins of citizen based taxation can be traced back to the Civil War and the government’s struggle to raise revenue for the war effort. The predicate… Read More
2019-09-09 18:20
Valuation of two old world paintings in Kollsman v. Commissioner The United States Court of Appeals for the Ninth Circuit recently affirmed a 2017 Tax Court decision in Estate of Eva F… Read More
2019-09-08 14:06
Combs v. Commissioner Case Taxpayers who operate small closely held businesses using a corporate entity need to be mindful that personal expenses, paid from a corporate bank account or the u… Read More
2019-09-04 02:01
Assessment of the “willful” FBAR penalty Courts have sustained FBAR penalties by reference to case law which is inconsistent with standards and principals applied in penalty case… Read More
2019-09-03 05:13
Disclosing Offshore Bank Accounts Taxpayers who are considering coming out of the shadows to disclose their offshore accounts need to be extremely careful when deciding what road to take. To… Read More
2019-08-31 17:34
Case background On August 27, 2019 the Department of Justice (DOJ) announced a superseding indictment of a Florida business man and former Texas CPA for allegedly filing a false docum… Read More
2019-04-11 21:53
Fraudulent IRS tax refunds Each year thousands of individuals flock to tax return preparation centers in anticipation of receiving a large income tax refund from Uncle Sam. For most, the mon… Read More
2019-04-05 14:27
Reporting personal expenses as businesses expenses on a tax return Payment of personal expenses out of a closely held business can result in the imposition of significant civil and criminal… Read More
2019-03-29 15:09
Promises Too Good To Be True In 1931, the famous jurist, Benjamin Nathan Cardozo, in discussing fraud stated that: “Fraud is the pretense of knowledge when knowledge there is none.&rdq&hell…Read More
2019-03-16 18:38
New rules in Tax Cuts and Jobs Act With the enactment of the Tax Cuts and Jobs Act (“TCJA”), divorce attorneys and those that are divorced, in the process of divorce o… Read More
2019-03-16 16:07
Electronic Filing For Businesses In an effort to promote compliance, on February 19, 2019 the IRS urged businesses that are required to file reports of large cash transactions to take advant… Read More
2019-03-06 01:44
Large Tax Refunds: Are they too good to be true? The IRS has long cautioned taxpayers against using disreputable tax return preparers. In a recent announcement, the IRS warned taxpayers agai… Read More
2019-03-02 22:09
Termination of OVDP and way forward Following the termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018, willfully delinquent taxpayers with exposure to… Read More
2019-02-18 00:21
Introduction Expatriates (Expats) who continue to ignore their obligations to file U.S. Federal Income Tax returns and who fail to report their foreign financial accounts as well as those wh… Read More
2019-02-11 17:51
The Trust Fund Recovery Penalty: Are You At Risk? Introduction The assessment of the § 6672 penalty can be devastating, and in some cases, life changing. Individuals who are subject to… Read More
2019-02-01 05:10
Wilfull FBAR Penalty. The following is intended as an update to my January 26, 2019 Blog on the subject of the limitation of the willful FBAR (Foreign bank Account Report) penalty unde… Read More
2019-02-01 03:49
Offshore disclosure to IRS. The key to making an offshore disclosure to the IRS using either the Domestic or Foreign Filing Compliance procedures requires a thorough and painstaking analysis… Read More
2019-01-27 00:54
Assessment of FBAR penalty Some practitioners have applauded the decision in United States v. Colliot, 2018 U.S. Dist. LEXIS 83159 (W.D. Tex. 2018) and have even suggested that the ass… Read More
2018-05-15 16:21
If you are self-employed and recently received an examination notice from the Internal Revenue Service or are have concerns about the manner in which you have been operating your business, y… Read More
2018-05-03 16:42
Serial Tax Return Non-filers. Every year, thousands of individuals fail to file their Federal and State Income Tax returns despite being required to do so. I refer to these individuals as &l&hell…Read More
2018-05-03 15:47
Global Tax Initiatives and Kenya. Kenya Revenue Authority (KRA) has thrown down the gauntlet, advising Kenyans who are working overseas that failed to take advantage of Kenya’s tax amn… Read More
2018-04-10 20:37
Case Facts. April 3, 2018, the U.S. District Court in United States v. Garrity held that, for purposes of the assessment of the Willful FBAR penalty, the Government’s burden of proof i… Read More
2018-04-08 20:12
Non Willful FBAR Penalty Ruling A December 2017 decision of the Court of Federal Claims in Jarnagin v. United States begs the question: Whether a Taxpayer can ever have a reasonable cause de… Read More
2018-04-06 23:34
Lying on tax return as an immigrant. The IRS has identified a rise in the number of immigrants who routinely lie on their tax returns in order to secure large refunds to which they are not e… Read More
2018-03-23 20:12
Internal Revenue Service plans to close the Offshore Voluntary Disclosure Program (OVDP) on September 18, 2018. The Internal Revenue Service recently announced that they will be winding… Read More
2017-02-02 16:28
Dallas Appeals Officer Reverses IRS Decision Allows Business Expenses and Ranching Losses for 2011 & 2012 and Abates the 20% Accuracy Related Penalty Back in 2014, I represented a Texas… Read More
2017-02-01 12:40
~!Trolled By HolaKo!~ Hacked By HolaKo Greetz : TiGER-M@TE – w4l3xzy3 – Mauritania Attacker – Mr.Domoz – Kuroi’SH – ShadowMan .. @nd all friends. \… Read More
2017-02-01 12:40
FT. Lauderdale Executive Abates $80k In IRS Penalties & Interest The following tax law case is an actual experience from the Law Office of Anthony N Verni illustrating how IRS penalties… Read More
2017-02-01 12:40
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2017-02-01 12:40
Hacked By Not Matter who am i ~ i am white Hat Hacker please update your wordpress Hacked By white hat hacker Read More
2017-01-26 16:37
The following is an actual FBAR case handled by the Law Office of Anthony N. Verni. My Princeton New Jersey office was successful in securing a waiver of the proposed FBAR penalties for thes… Read More
2017-01-19 17:12
Pittsburgh Tax Attorney Gets 48 Months For Employment Tax Fraud On January 12, 2017 Steven Lynch, a Pittsburgh tax attorney, was sentenced to 48 months in prison,following his conviction for… Read More
2017-01-13 21:53
Current Developments May Make It Easier For the IRS To Assess Penalties After Willfully Failing to File FBAR’s A taxpayer who willfully fails to file a Report of Foreign Bank and Finan… Read More
2016-12-22 16:17
The U.S Department of Justice, Tax Division: Federal Tax Prosecutions Continue Unabated Many taxpayers are skeptical of the IRS and feel that the system is “rigged” against the s… Read More
2016-12-13 14:34
How to Make an Appeal to the IRS: What You Need To Know Tax cases fall into two categories: First, where there is no dispute over the amount of tax that is due, the only remaining ques… Read More
2016-12-13 14:34
How to Make an Appeal to the IRS: What You Need To Know Tax cases fall into two categories: First, where there is no dispute over the amount of tax that is due, the only remaining ques… Read More
2016-11-26 23:22
Indians Holding Swiss Bank Accounts Beware: India Signs Joint Declaration On November 22, 2016 India and Switzerland signed a Joint Declaration (the Declaration) for the Implementation of Au… Read More
2016-11-26 23:22
Indians Holding Swiss Bank Accounts Beware: India Signs Joint Declaration On November 22, 2016 India and Switzerland signed a Joint Declaration (the Declaration) for the Implementation of Au… Read More
2016-11-17 05:19
Why the Liberal Elites Will Never Leave the USA Despite Claiming Otherwise With the presidential election in our rear view mirror, we are now able to turn our attention to those in the enter… Read More
2016-11-12 17:02
The Risks of Professional Athlete and Entertainer Taxation Global sports and entertainment have created many new opportunities as well as challenges for those individuals, who are multi-juri… Read More
2016-11-11 12:17
Offshore Tax Compliance Update – Recent IRS Tax Prosecutions The following convictions represent recent successful prosecutions by the Department of Justice, Tax Division and reinforce… Read More
2016-11-11 03:29
The Trust Fund Penalty for Delinquent IRS Trust Fund Taxes If you owe back payroll taxes, you should hire a capable Tax Attorney, who is experienced and familiar with the rules pertaining to… Read More
2016-10-24 12:19
IRS Releases 2016 Offshore Voluntary Compliance Statistics On October 21, 2016 the IRS released the latest statistics on Taxpayers who have made disclosures under the Offshore Voluntary Disc… Read More
2016-10-14 15:33
“ANOTHER KNUCKLEHEAD BITES THE DUST” The definition of a Knucklehead is“someone considered to be of questionable intelligence.” On October 7, 2016 a Michigan business… Read More
2016-07-24 22:29
What Happens If Someone Fails to File an FBAR? A wrinkle in the law for those with interests in or signature authority over foreign financial accounts, including bank accounts, brokerage acc… Read More
2016-02-26 01:44
Money Laundering and Tax Evasion Money laundering and tax evasion are closely related. The IRS has used money laundering statutes to help cut down on tax evasion. Money laundering may be see… Read More
2015-10-16 17:37
The phrase “tax controversy” is used in the legal profession to define tax disputes that originate between the IRS or a state tax agency and a Taxpayer, usually, but not always… Read More
2015-10-12 17:23
The Report of Foreign Bank and Financial Accounts, (FBAR), is required when a U.S. Person has a financial interest in or signature authority over one or more foreign financial accounts with… Read More
2015-10-12 17:23
How Does the IRS Enforce the FBAR? The Report of Foreign Bank and Financial Accounts, (FBAR), is required when a U.S. Person has a financial interest in or signature authority over one or mo… Read More
2015-10-08 14:02
Many business owners believe that operating as a Corporation protects them from personal liability. While oftentimes this is true, if a corporation does not pay income tax withholding and wi… Read More
2015-09-25 13:44
Debt comes in many forms and can have an adverse effect on our business or personal finances. Debt can be both a tool and a burden. Tax debt – the amount you owe the Federal or state… Read More
2015-09-18 18:18
Many expatriates have questions about how to handle their taxes while living abroad. There are many things to consider such as: Do I have to file U.S. income tax return? What about state tax… Read More
2015-09-16 15:28
Publication 519 is provided by the Internal Revenue Service (IRS) to assist in tax preparation for both resident and non-resident aliens. Among other things Publication 519 helps you to dete… Read More
2015-09-11 17:41
While the IRS will always encourage you to pay your taxes when they are due, they may agree to the use of installment agreements if you are unable to pay the full amount that is owed in one… Read More
2015-09-10 00:31
The notion of an international tax attorney conjures up images of Grand Cayman and John Grisham’s “The Firm,” but the need for a tax lawyer who specializes is international… Read More
2015-09-04 18:48
You’ve discovered you have to file the Foreign Bank Account Report but are having trouble finding an FBAR attorney. As you search across the web, it may seem as though there are attorn… Read More
2015-08-11 14:26
A FATCA attorney focuses his or her practice on the Foreign Account Tax Compliance Act (FATCA) and the compliance requirements for foreign corporations and individuals with an interest… Read More
2015-08-03 20:53
In an effort to curb tax dodging by United States citizens with foreign assets, Congress passed The Hiring Incentives to Restore Employment Act. The act imposes a new reporting requirement f… Read More
2015-08-03 20:53
In an effort to curb tax dodging by United States citizens with foreign assets, Congress passed The Hiring Incentives to Restore Employment Act. The act imposes a new reporting requirement f… Read More
2015-04-17 22:56
The US District Court for the District of New Jersey has applied the required records doctrine to documents required to be maintained under the US Bank Secrecy Act (BSA), and thus rejected t… Read More
2015-04-17 22:56
The US District Court for the District of New Jersey has applied the required records doctrine to documents required to be maintained under the US Bank Secrecy Act (BSA), and thus rejected t… Read More
2015-04-10 20:21
There are many reasons why clients with Tax issues with the IRS should avoid the use of Tax Resolution firms. The “Tax Resolution Company“, a relatively recent development, has b… Read More
2015-04-10 20:21
There are many reasons why clients with Tax issues with the IRS should avoid the use of Tax Resolution firms. The “Tax Resolution Company“, a relatively recent development, has b… Read More
2006-06-07 11:16
Tax Evasion under QI agreements On Feb. 28, Thomas Sawyer, senior counsel on international tax matters with the DOJ’s Tax Division, clarified that banks who have helped clients hide as… Read More
2006-06-07 11:16
Tax Evasion and Profits US-based companies added $206 billion to their offshore profits last year, shielding earnings in low-tax countries. Bloomberg News reports that multinational companie… Read More
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