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Posts Tagged Michigan tax attorney

FBAR Penalties and the Definition of “Willful”

U.S. taxpayers are required to report offshore financial holdings when the aggregate balance of those assets exceeds $10,000. Even if your foreign brokerage account exceeds $10,000 in value for just 1 day, federal law requires the account be reported on a Report of Foreign Bank and Financial Accounts – FBAR for short. The FBAR penalties [...]

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Do You Have The Right To Rely on IRS Forms? Court Says “Maybe” – FBAR Post

A federal jury in South Bend, Indiana convicted James Simon of filing false tax returns and of failing to file FBARs. As regular readers of this blog know, the willful failure to file an FBAR is a felony. Following his conviction, Simon appealed. In a lengthy opinion, the US. Seventh Circuit Court of Appeals upheld [...]

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Wisconsin Court Rules Concert Co-Promoter Liable For Unpaid Taxes

A Wisconsin Circuit Court judge upheld a decision of the state’s Tax Appeals Commission, finding a concert “co-promoter” liable for unpaid taxes. The decision highlights how businesses can be held responsible for unpaid taxes even if they had no role in collecting the taxes. The Riverside Theatre in Milwaukee is a popular venue for concerts. [...]

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Audit Defense Post – Where Do You Really Live?

As the demand for government services increases, so do state and local governments’ appetite for tax revenues. In recent years we have seen more instances where two states claim the same taxpayer as a resident for tax purposes. More often, the situation occurs when a taxpayer claims to have changed his legal domicile but continues [...]

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IRS Seeks To Tax “Stateless Income” – Business Tax Post

Here is a new term for you, “stateless income.” Thought to have been coined by a Congressional staffer in 2007, the IRS has apparently adopted the term – and the cause. Stateless income occurs when a company structures itself such that its profits are not taxed in any jurisdiction. An IRS deputy chief counsel announced [...]

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