stamford ct: Stamford CT IRS Criminal Tax: Venue for Failure to File FBAR Lies in Any District that Houses an IRS Office
- 12/07/11 12:59 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for failure to file an FBAR properly lies in any district that houses a local IRS office, so long as the chosen venue does not create a constitutional hardship for the defendant. As discussed above, the Bradleys and their company, Bio–Med Plus, Inc., engaged in multiple schemes to defraud the Florida and California Medicaid programs … (0 comments)
stamford ct: Stamford CT IRS Criminal Tax: Fifth Amendment Privilege Held to be Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act
- 12/07/11 12:50 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign bank account records required to be kept under the Bank Secrecy Act (“BSA”) fall within the Required Records Doctrine, thus rendering the Fifth Amendment privilege against self-incrimination inapplicable to a subpoena for these records. When I am asked by clients about records demanded by the government, I often have to explain that records required … (0 comments)
Bloomberg is reporting that U.S. and Swiss officials are concluding negotiations on a civil settlement amid U.S. criminal probes of 11 financial institutions suspected of helping American clients hide money … (0 comments)
stamford ct: Stamford, CT IRS Gift Tax Returns: The Internal Revenue Service is Now Using State Property Records To Identify taxpayers Who Fail to File a Gift Tax return in Stamford, Connecticut and Elsewhere
- 10/28/11 11:46 PM
We frequently represent taxpayers before the Internal Revenue Service (“IRS”) in all types of civil and criminal tax controversies. It is now being widely reported that the IRS has instituted a new gift tax compliance initiative, which is designed to respond to its suspicions of widespread failure to file gift tax returns. According to the IRS Federal/State Coordinator for Estate & Gift Taxes, Josephine Bonaffini, between sixty percent and ninety percent of taxpayers fail to file a gift tax return despite having engaged in a transaction requiring a return. According to Bonaffini, in the past two years, 323 taxpayers have been … (0 comments)
stamford ct: Stamford, CT DRS Contractors: The DRS Releases Special Notice 2011(17) Explaining the Amendments Affecting the Requirement for Nonresident Contractors to Provide Bonds.
- 10/28/11 11:11 PM
We represent taxpayers before the Connecticut Department of Revenue Service (“DRS”) frequently. A hot button issue for the last few years has been the issue of nonresident contractors and the requirement to provide a bond. The law requiring nonresident construction contractors to furnish security for Connecticut taxes arising from jobs performed in Connecticut has been changed in the following major ways: · Under the law as amended, there are two classes of nonresident contractors: verified and unverified. A nonresident prime or general contractor may gain verified status and thus eliminate the requirement to file a surety bond with the Department of … (0 comments)
stamford ct: CCH Presentation on Advanced Criminal Tax Issues
- 10/28/11 08:31 AM
On Wednesday November 9th I will be presenting on a national Webinar for CCH, A Wolters Kluwer Company "Advanced Criminal Tax Issues: Protect Your Clients and Yourself" You can get more information and register for this program at the link below: http://online.krm.com/iebms/reg/reg_p1_form.aspx?oc=10&ct=0010300&eventid=18543
Make sure you understand the IRS criminal investigation process to avoid creating problems for your clients and your practice.When IRS criminal investigators begin looking at a taxpayer, the stakes change. As an advisor, your own freedom can be put at risk in such situations. It's not a time to learn as you go. In this two-hour CPE webinar … (0 comments)
stamford ct: IRS Tax Lien Subordination in Stamford, Connecticut: Having the IRS agree to subordinate its lien for a new creditor may not be as taxing as you thought!
- 10/26/11 03:50 PM
We frequently represent clients who have a federal tax lien for outstanding IRS federal tax debt and can now obtain financing from a new creditor who insists the IRS subordinate its lien to their lien. The IRS often agrees to a subordination, which means that it will agree, in writing, to allow another creditor to lend money to the taxpayer and have that lenders lien take priority over the existing IRS tax lien. Inn order to obtain a subordination, we make a written request with very specific information that demonstrates how the IRS’s ability to collect the old tax debt will … (0 comments)
stamford ct: IRS Offer-in-Compromise in Stamford, Connecticut: How does the IRS determine what to accept for an Offer-in-Compromise?
- 10/26/11 03:47 PM
We frequently represent clients who want to resolve their outstanding IRS federal tax debt with an Offer-in-Compromise in Stamford, Connecticut often ask us how much they have to offer? The truth is it depends upon the individual’s personal financial situation. The IRS looks to obtain what it can based upon the taxpayer’s Reasonable Collection Potential, or “RCP.” It is the RCP that will determine whether the taxpayer’s Offer-in-Compromise is ultimately accepted by the IRS. So what is involved with the RCP? For our clients in Stamford, Connecticut and elsewhere, the RCP consists of what the IRS could expect to collect from … (0 comments)
stamford ct: IRS Criminal Prosecutions of Preparers Stamford, Connecticut: The IRS continues its focus on tax return preparers who assist clients with the filing of false tax returns.
- 10/26/11 03:45 PM
We frequently represent tax return preparers who find themselves the target of an IRS criminal investigation. These issues often start when the IRS picks up on issues with a client or two, who without any other excuse point the finger at the tax preparer to deflect the blame from themselves. Internal Revenue Code Section 7206 makes it a crime for anyone to assist a taxpayer in the preparation and/or filing of a false tax return. Internal Revenue Code Section 7201 for tax evasion is also an oft used weapon by the IRS, as defendants don’t have to be evading their … (0 comments)
stamford ct: IRS Criminal Payroll Tax prosecutions in Stamford, Connecticut: If you owe payroll taxes, beware: the IRS prosecution of employers is on the upswing.
- 10/26/11 03:43 PM
We frequently represent clients who owe significant sums of back payroll taxes, to the IRS. For years it was rare to see a criminal prosecution for unpaid payroll taxes, but that is no longer the case. We have seen a significant increase in IRS criminal prosecutions, and it appears payroll taxes are a new IRS Criminal Division priority. Internal Revenue Code Section 7202 makes it a crime for an employer to willfully fail to account for and pay over payroll taxes. We always advise our clients in Stamford, Connecticut and elsewhere to take serious steps to resolving their outstanding payroll … (0 comments)
stamford ct: IRS Foreign Bank Accounts Stamford, Connecticut: The IRS continues its assault on hidden foreign bank accounts with its relentless prosecutions.
- 10/26/11 03:40 PM
We frequently represent clients who have hidden bank accounts in foreign countries and would like to come forward and clean up their issue and sleep better at night. Prior to 2009 we did through a voluntary disclosure with the IRS criminal division. Since 2009 there have been two voluntary disclosure initiatives (the 2011 one ends August 31st). If sleeping better at night and reduced penalties with reduced risk of criminal prosecution was not enough of an inducement, the recent headlines should be. Reading the IRS announcements that have been streaming out of its criminal investigations division makes for interesting reading. The … (0 comments)
stamford ct: IRS Criminal Payroll Tax Cases Stamford, CT: IRS Criminal Division begins focusing on criminal payroll tax cases.
- 10/26/11 03:37 PM
With the recent uptick in enforcement by the IRS comes a new trend in criminal tax prosecutions of payroll tax cases. Whether your business is located in Stamford, Connecticut or elsewhere, the failure to collect and pay-over the payroll taxes may create more than just financial problems for you. We frequently represent taxpayers having a difficult time paying their payroll tax obligations to the IRS. In general these matters remain civil issues with the IRS and we help our clients resolve these matters either through installment agreements or by filing an offer in compromise. However, there has been a significant increase … (0 comments)
stamford ct: IRS Levy in Stamford Connecticut: Dealing with an IRS bank levy in Stamford, Connecticut.
- 10/26/11 03:34 PM
We frequently represent taxpayers who live in the Stamford, Connecticut area and other areas of Connecticut who have had the IRS levy their bank accounts or other assets, seizing assets and wreaking havoc on their business and personal lives. The number one priority for these taxpayers is having the IRS levy released. Next is avoiding another IRS levy. We handle these issues all the time, and the first thing taxpayers should realize is that an IRS bank levy is not a continuing levy, meaning it only attaches to those assets the taxpayer owns at that moment. For instance, if the IRS … (0 comments)
stamford ct: Tax Compliance Stamford Connecticut: Want to resolve your outstanding tax issue in Stamford, Connecticut? Get into tax compliance!
- 10/26/11 03:32 PM
We frequently appear before both the Internal Revenue Service (“IRS”) and Connecticut Department of Revenue Services (“DRS”) on behalf of taxpayers in Stamford, Connecticut as well as other parts of the state, and tax compliance is almost always raised as an issue. So what is “Tax Compliance” and what is its importance to your case? What tax compliance means is that the taxpayer is currently complying with the tax laws, which means that: All past due tax returns have been filed They are having the proper tax withholding done currently if they are an employee, or if they are self-employed, they … (0 comments)
stamford ct: IRS Tax Fraud Stamford, CT: Beware extending the statute of limitations for an IRS audit if there are indications of Fraud
- 10/26/11 03:30 PM
When of the biggest pitfalls for a taxpayer or their representative in Stamford, CT or elsewhere is to extend the statute of limitations for a civil IRS exam where there are indications that tax fraud has occurred. We handle a significant number of civil examinations as well as represent taxpayers in criminal investigations by the IRS, and can tell you that requesting an extension for the three-year statute of limitations is a frequent IRS tactic to use when there is a criminal tax fraud investigation going on behind the scenes. The general rule is that the IRS has three years to … (0 comments)
News, updates and innovative discussion of what is happening in the world of estate planning, tax planning, and criminal and civil taxpayer representation.
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for failure to file an FBAR properly lies in any district that houses a local IRS office, so long as the chosen venue does not create a constitutional hardship for the defendant.
;)
;)
;)
