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Posts Tagged offshore accounts

Government’s Appeal of FBAR Penalty Loss Headed to Hearing

by Brian Mahany
For the few lawyers that extensively help taxpayers with offshore reporting and FBAR problems, the case of United States v. J. Bryan Williams decided in 2010 was a watershed moment. For those not familiar with the case, Bryan Williams was convicted of tax evasion and conspiracy to defraud the IRS back in 2003. [...]

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Show Down Time Between US IRS and Swiss Banks

by Brian Mahany
The US government’s deadline for 11 Swiss banks to turn over names came and went on Tuesday. Although Credit Suisse has apparently agreed to comply, Swiss news source Swiss Info says the banks are remaining “tight lipped.”
The IRS is seeking not only the names of US account holders but correspondence between the bank [...]

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New Foreign Asset Reporting Begins January 1st

by Brian Mahany
Just as the dust starts to settle on the offshore amnesty (OVDI) and FBAR rules, the IRS gives us a new form with more rules and more penalties for the unwary.
As part of the Foreign Asset Tax Compliance Act (FATCA) and the Hire Act of 2010, Congress mandated that for tax years beginning [...]

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Filing Delinquent FBARs in a Post Amnesty World

by Brian Mahany
Amnesty has been over for months and yet many people still have not reported their offshore accounts to the IRS. For some the decision is intentional. For many others, they only just became aware of the law.
The vast majority of offshore account holders are not multimillionaires with hidden Swiss [...]

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