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Jun 07, 2021

Are U.S. Corporate Tax Hikes Coming? Are Corporate Profit-Shifting to Low-Tax Off-Shore Jurisdictions at Risk?

On May 18, Department of the Treasury Secretary Janet Yellen addressed the U.S. Chamber of Commerce at their Global Forum on Economic Recovery, continuing her pitch to raise corporate taxes and reduce or eliminate the current incentives for sourcing corporate profits off-shore to low-tax countries.» Read More

Jun 16, 2014

Offshore Disclosure Developments Continue: FBAR Deadline Is June 30

On June 3 at the OECD International Tax Conference, the IRS Commissioner John Koskinen said the IRS expects to make modifications to its offshore voluntary disclosure program shortly that will likely lessen the penalties for those with unreported offshore accounts whose compliance failures have been non-willful.» Read More

Apr 24, 2014

The IRS Offshore Voluntary Disclosure Program Continues

It has been more than two years since the IRS launched the third official offshore voluntary disclosure program (“2012 OVDP”.) In its current form, 2012 OVDP has no set closing date. It is meant to bring U.S. taxpayers into compliance by offering them a fitted approach to filing informational returns and amending their tax returns for unreported offshore income without criminal proceedings.» Read More

Feb 28, 2014

Has the IRS Found Its OVDP Mojo, Just like Austin Powers?

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For some time now, the IRS has been focusing on offshore income and offshore assets. Since 2009, the IRS has had three different offshore voluntary disclosure initiatives, designed to offer amnesty to non-compliant U.S. taxpayers who would like to come forward to straighten out the federal income tax situation and their informational filing situation (commonly FBARs).» Read More

Jan 24, 2014

SEMINAR: Hot Tips in Taxation 2014, Wednesday, January 29

My colleague Jill Lebowitz and I will be speaking at the New Jersey Institute for Continuing Legal Education’s  seminar, “Hot Tips in Taxation 2014,” on Wednesday, January 29, at the New Jersey Law Center.  The NJICLE is presenting the seminar in cooperation with the New Jersey State Bar Association’s Taxation Section.» Read More