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The incredible things we’ve learned as OVDP lawyers

Our work as Offshore Voluntary Disclosure Program (OVDP) attorneys is rewarding. Working with our dynamic clients, getting to know them, their families, while doing our best to mitigate the risk and damage the IRS intend to cause --- we feel great because the work we do is incredibly consequential.

How you can avoid being charged with a Federal Tax Crime

Did you know that --- that in theory --- it is actually fairly hard for the US government to get a tax evasion conviction. However, because so many practitioners don't fully understand how the system works, they mistakenly have their clients fall into the same old trap year after year. In this article we will explain how you can avoid the mistakes of others.

How Federal Tax Amnesty Programs work

IRS problems can sneak up on anyone. But not everyone's circumstances are the same. When solving a tax problem, the best option for your neighbor might not be the best option for you. In this article, we are going to go over some of the tights spots Americans get themselves into each year and the best federal tax amnesty programs for each situation.

How to avoid a federal tax evasion indictment or conviction

Being convicted of a federal tax crime can shatter your life. While the IRS moves slowly, unfortunately, when the IRS does finally sets their sights on you, life can become fairly miserable. This is not to say everyone who owes the IRS money or has unfiled taxes or unreported foreign accounts will be indicted and convicted...

Was your IRS Offshore Voluntary Disclosure submission declined?

If you have made what you thought was a timely and complete Pre-Clearance or Offshore Voluntary Disclosure Program (OVDP) submission, you may be wondering why you were denied or rejected. The good news is there are alternatives available to...

DOJ muffs up international asset reporting rules

The issue I have with the quoted paragraph is the claim that taxpayers must "identify the country where the account was maintained." But this is only true if the FBAR... Saul Hyatt, 53, pleaded guilty today before U.S. District Judge Freda L. Wolfson of the District of New Jersey to an Information charging him with conspiracy to conceal assets in an undeclared bank account held in Panama for his ...

The complete outrage: IRS structuring laws

If the government decides someone is guilty of structuring, they can be charged with a felony punishable by a fine and/or up to five years in prison. And? They can swoop in and clean out your bank account. No questions asked, no trial, no proof that you are doing something wrong.

The FBAR win that didn't include an FBAR

A recent tax court case had many of us excited about the government losing an FBAR penalty case and the impact it could have for taxpayers. Unfortunately, upon further review, while the taxpayer deserves congratulations for his impressive and complete win, this particular case was limited in...

Not a duplicate post: Yes, three more Swiss banks "blacklisted"

UPDATE 11/24/2015: Privatbank IHAG Zürich AG (IHAG) has also reached a resolution under the department’s Swiss Bank Program. If our posts feel a little bit like déjà vu, there may be a reason. On Tuesday, we wrote how the IRS had added three more Swiss banks to the Foreign Bank ...

Working out a tax settlement with the IRS

Ready for a shocker? You can negotiate with the IRS. Not only can you negotiate, but if you do it well, you can turn an overwhelming debt into something reasonable. As someone who negotiates with the IRS on a daily basis, I find myself saying ...

6 ways to tell if an IRS call is a scam

Oh those tricky IRS scammers are still out there; we first noticed this phenomenon a few years ago, as well as the IRS. And it hasn't stopped. In this article, we have listed six things to listen for when you get a call from someone who claims to be from the IRS.

More Blacklisted Swiss Banks: What to do when the IRS takes over

On Thursday (October 29, 2015), the US Department of Justice announced new additions to the Swiss Bank Program that will soon be added to the "Blacklisted" Foreign Financial Institutions List: Luzerner Kantonalbank AG (Luzerner), Habib Bank AG Zurich (HBZ), Banque Heritage S.A.,Hyposwiss Private Bank Genève S.A. (Hyposwiss Geneva)

Offshore Tax Problems: It's good to be the king

Since the 2011 Offshore Voluntary Disclosure Initiative was first announced, and as it has evolved into the full - fledged 2012 Offshore Voluntary Disclosure Program (OVDP) and eventually into the current 2014 OVDP complete with the Streamlined Procedures, I have been fairly consistent in ...

How to Negotiate with the IRS: Criminal Investigations

This is Part I of our three - part series on "How to Negotiate with the IRS." In this video, I discuss the very uncomfortable prospect of a criminal investigation or grand jury indictment. The takeaway - every situation can be made better. ANTHONY PARENT: Today’s show is going to be ...

Singapore banks getting offshore scrutiny?

There is somewhat of an open secret among offshore tax experts that many US person with unreported foreign accounts have either: Converted the assets to cash and have placed it into ever - growing safety deposit boxes; or Attempted to move the funds to countries less interested in ...

Tax Crimes and the Department of Justice

Here's a painful truth that I've seen time and time again - the majority of taxpayers are not in tune with how serious tax crimes are. The Department of Justice (DOJ) and how they deal with tax crimes are off the radar of most U.S. citizens, but the consequences can be far - reaching. ...

New IRSMedic Webinar: What to do when your offshore bank is "blacklisted"

We're going to cover what we mean by 'blacklisted' bank, about what your options are, if you can go streamlined, when an opt out in the OVDP makes sense, and about the traps of doing a 'soft' or 'quiet' disclosure.

FinCEN claims "investment adviser" means "financial institutions"

The Financial Crimes Enforcement Network (FinCEN) is the part of the US Treasury tasked with administering the FBAR Form. Even though their job is to administer the FBAR, they tend to assign most of their administrative tasks to the IRS. And now they're messing around with...

Another day, another 3, no, 7, no, 10 Swiss banks enter into Non-Prosecution Agreements with the IRS

Hmm... I'm starting to detect a pattern of sorts when it comes to Swiss banks and their interactions with the IRS. It's almost as if every small, private Swiss bank has entered or will enter into a non - ...

Feeling lucky? Take a gamble on IRS Forms 11-C and 730

Recently I found myself taking a look at the taxation of gambling. But, just so we're all on the same page, I'm not talking about income tax due from gambling. Instead, we're focusing on the excise taxes imposed on gambling, which include... illegal gambling!

Three more Swiss banks on 50% offshore penalty list

Privatbank Von Graffenried AG (effective 7/2/15), Banque Pasche SA (effective 7/9/15), and ARVEST Privatbank AG (effective 7/9/15) have been added to the IRS OVDP FAQ 7.2 Foreign Financial Institutions or Facilitators list. We've talked about what it means when your bank has been added ...

Common OVDP FAQ 7.2 questions answered

The Offshore Voluntary Disclosure Program can feel overwhelming to understand. Let's tackle some of the more common questions we receive about the program, such as: What does being on the Foreign Financial Institutions or Facilitators list mean? and The 50% penalty sounds unreasonable. What other...

An OVDP closing agreement that didn't close?

We have been seeing a relatively new phenomenon lately: The IRS and Department of Justice (DOJ) requesting testimony or documentation from a person going through the OVDP (Offshore Voluntary Disclosure Program ) --- or a person who has already completed an Offshore Voluntary Disclosure, signed a Letter 906 and paid all...

Attorney-Client Privilege, John Doe Summons, and Sovereign Management & Legal

Will attorney - client privilege protect you from a John Doe summons? Popular belief seems to suggest that attorney - client privilege covers everything. Well, I hate to be the bearer of bad news, but it really doesn't. A recent summons on the part of a New York judge has brought this reality ...

Premier Offshore Investor

Update on Premier Offshore Investor - 1/19/2015: Chris Rusch contacted me and indicated that he has had nothing to do with Premier Offshore since 2013. He tells me he no longer has associations with Live and Invest Overseas or International Living. Here is what he sent ...

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