Another blow to U.S. efforts to breach foreign privacy protection

February 11, 2010

The U.S. wants to know all about financial transactions. While the ostensible reason is to fight Columbian druglords terrorism, the U.S. government’s urge to tax runs an extremely close second place.
Thanks to my correspondent Don for sending me a link to a news item from the BBC which describes an action of the European [...]

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Tell your offshore bank account story anonymously on our forums

February 10, 2010

There are a lot of you out there who have a story to tell about the offshore bank account amnesty. Public perception and IRS PR is at odds with the experiences of ordinary people like you. Only one side of the story is being told.
The amnesty penalties are disproportionate to the tax due. [...]

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Bravo House Ways & Means Committee for RSS

February 9, 2010

I was trolling through the House Ways & Means Committee website looking for hints of the existence of H.R. 4539, a new bill which significantly alters the taxation of nonresident investors in U.S. real estate.
To my utter shock, I found that our trusted servants have enabled RSS for Committee activity.
Bravo!
(If anyone else is interested in [...]

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Pre-immigration tax planning: calculate the tax cost of immigration

February 8, 2010

I am writing a series of blog posts about pre-immigration tax planning. What should you do — for tax planning — if you wish to become a U.S. resident?
This is the fifth post. Prior posts are found here: Post 1, Post 2, Post 3, and Post 4.
If you have any questions or comments [...]

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German tax authorities and stolen data – report from John Nolan in Frankfurt

February 8, 2010

I received this email from John Nolan, an attorney in Frankfurt, and reproduce it with permission:

Phil,
A quick update from the weekend German press:

The CD with an estimated 1,500 names that has been offered to (and sampled by) the tax authorities of the German state of Nordrhein-Westphalen (administration of German federal taxes is conducted at the [...]

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Pre-immigration tax planning: tax rules for residents vs. nonresidents

February 7, 2010

I am writing a series of blog posts about pre-immigration tax planning. What should you do — for tax planning — if you wish to become a U.S. resident?
This is the fourth post. Prior posts are found here: Post 1, Post 2, and Post 3.
If you have any questions or comments I would [...]

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Pre-immigration tax planning: Federal tax rules for being a resident

February 6, 2010

I am writing a series of blog posts about pre-immigration tax planning. What should you do — for tax planning — if you wish to become a U.S. resident?
This is the third post. Prior posts are found here: Post 1 and Post 2.
If you have any questions or comments I would love to [...]

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Pre-immigration planning: U.S. bureaucracies and resident status

February 5, 2010

I am writing a series of blog posts about pre-immigration tax planning. What should you do — for tax planning — if you wish to become a U.S. resident?
This is the second post. The first post is here.
If you have any questions or comments I would love to hear them. Send an [...]

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Why the Voluntary Disclosure Program is off the rails and how to fix it

February 5, 2010

I have been thinking a lot about the Voluntary Disclosure Program and enforcement of tax violations by the IRS. The recent guilty plea by Jack Barouh clarified things for me a bit. Yeah, I’m a slow learner. It took 29 years of practice and watching 7 guilty pleas go by for me [...]

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More on Jack Barouh, the seventh UBS conviction

February 5, 2010

Yesterday I posted the news about the seventh conviction by the Department of Justice of a UBS-related tax evasion case.
Here is the press release from the Department of Justice announcing their triumph.
One of my correspondents emailed me the Statement of Facts (PDF for download) for the Barouh case, published by BNA. [...]

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