By: Anthony N. Verni Attorney at Law, CPA September 5, 2024 ©2024   Eleventh Circuit Sustains Willful FBAR Penalty, But throws the Taxpayer a Bone On September 4, 2024, the Un… Read More

By: Anthony N. Verni, Attorney at Law, CPA August 13, 2024 ®2024 EMPLOYMENT TAX AUDITS ON THE RISE SECTION 6672 PENALTY AND CRIMINAL PROSECUTION Employment tax audits are on the rise and… Read More

By: Anthony N. Verni, Attorney at Law, CPA August 13, 2024 ©2024   TAXPAYER’S ADHD DIAGNOSIS, STRESS, DEPRESSION AND STAGE 3 PROSTRATE CANCER NO DEFENSE TO WILLFUL FBAR PENAL… Read More

By: Anthony N. Verni, Attorney of Law, CPA Date: August 6, 2024 ©2024   PERMANENT LAWFUL RESIDENT PROCEDURES FOR U.S. TAX EXPATRIATION Any decision regarding expatriation from the… Read More

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

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

  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

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

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

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

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

  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

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

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

By: Anthony N. Verni, Attorney at Law, Certified Public Accountant November 3, 2022 ©2022                           &nbs… Read More

  By: Anthony N. Verni, Attorney at Law, Certified Public Accountant Date: November 1, 2022 ©2022                        … Read More

By:          Anthony N. Verni, Attorney at Law, Certified Public Accountant Date:     October 22, 2022 ©    &n… Read More

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

  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

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

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

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

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

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

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

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

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

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

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

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

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

 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

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

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

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

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… Read More

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

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

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

 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

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

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

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

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

  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

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

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

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… Read More

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

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