Offshore Disclosure Lawyer fees Flat-Fee or Hourly Offshore Disclosure Lawyer Fees Offshore Disclosure Attorneys Fees: Flat-Fee or Hourly? With the IRS having both closed OVDP (2018) and ended DIIRSP (2020), the big question is whether Streamlined may be next up on the chopping block. If you are considering attorney representation in offshore disclosure matters, one important component of representation is whether counsel charges hourly or flat-fee. Experienced Offshore Disclosure counsel always charge flat-fees and…
Reasonable Cause & IRS Tax Penalties Reasonable Cause & IRS Tax Penalties Reasonable Cause & IRS Tax Penalties: When a non-willful taxpayer faces potential penalties for failing to comply with the Internal Revenue Code, they may be penalized by the IRS. The taxpayer may be able to avoid, minimize, or abate the penalties if the taxpayer can establish reasonable cause. Ideally, it is better for the taxpayer to avoid the penalty than it is…
  Foreign Investment Accounts and FBAR Foreign Investment Accounts & FBAR Foreign Investment Accounts & FBAR: When it comes to the FBAR and US Persons, one of the most complicated aspects of reporting foreign bank and financial accounts is just trying to determine which accounts are included on the form. For reference, the FBAR is a FinCEN form, but it is enforced by the IRS. While most people are aware that FBAR filing…
2020 Yearly Average Currency Exchange Rates 2020 IRS Yearly Average Currency Exchange Rates  2020 Yearly Average Currency Exchange Rates: The Internal Revenue Service does not require taxpayers to use any specific exchange rate. The exhcange rate should be reasonable, as to not bring on any unnecessary scrutiny from the IRS. Each year, the IRS publishes the average exchange rate. Recently, they published the average exchange rate for the tax year 2020, which has been…
2020 Yearly Average Currency Exchange Rates 2020 IRS Yearly Average Currency Exchange Rates  2020 Yearly Average Currency Exchange Rates: The Internal Revenue Service does not require taxpayers to use any specific exchange rate. The exhcange rate should be reasonable, as to not bring on any unnecessary scrutiny from the IRS. Each year, the IRS publishes the average exchange rate. Recently, they published the average exchange rate for the tax year 2020, which has been…
2020 Yearly Average Currency Exchange Rates 2020 IRS Yearly Average Currency Exchange Rates  2020 Yearly Average Currency Exchange Rates: The Internal Revenue Service does not require taxpayers to use any specific exchange rate. The exhcange rate should be reasonable, as to not bring on any unnecessary scrutiny from the IRS. Each year, the IRS publishes the average exchange rate. Recently, they published the average exchange rate for the tax year 2020, which has been…
FinCEN Notice 2020-2 FBAR Cryptocurrency Virtual Currency FinCEN Notice Proposes New FBAR Cryptocurrency Reporting FinCEN Notice Proposes FBAR Cryptocurrency Reporting: For many years, our international tax lawyers have authored a variety of different FBAR articles, and counseled many taxpayers worldwide on FBAR issues involving offshore cryptocurrency. Dating back many years to when cryptocurrency became an online phenomenon, we have always taken the position in our prior articles that sooner or later the US government would…
FinCEN Notice 2020-2 FBAR Cryptocurrency Virtual Currency FinCEN Notice 2020-2 & FBAR Crypto Reporting FinCEN Notice 2020-2 & FBAR Crypto Reporting Requirements: For many years, our international tax lawyers have authored a variety of different FBAR articles, and counseled many taxpayers worldwide on FBAR issues involving offshore cryptocurrency. Dating back over 10-years ago to when cryptocurrency became an online phenomenon, we have always taken the position in our prior articles that sooner or later the…
International Tax Attorneys International Tax Attorneys International Tax Attorneys: Golding & Golding specializes exclusively in international tax and offshore tax compliance, disclosure and reporting. IRS international tax is the only area of tax practice our lawyers handle. Each case is led by a Board-Certified Tax Lawyer Specialist. Over the years, we have helped thousands of Taxpayers nationwide from New York to Washington DC, Florida, Texas, California, and more with complex international tax matters. We have represented…
FBAR Statute of Limitations FBAR Statute of Limitations FBAR Statute of Limitations: The FBAR statute of limitation rules are different than other IRS Tax enforcement rules. That is because the FBAR refers to U.S.C. title 31 (Money and Finance) and not title 26 (Internal Revenue Code). FBAR reporting relates to offshore reporting of foreign account, asset, and investment value — not income. The IRS has taken an aggressive approach to foreign accounts compliance. Still,…