Update: As of November 21, 2019, various news sources are reporting that Former Mayor Pugh has pleaded guilty to four of the 11 charges in an executed plea deal. According to these reports, she pleaded guilty to at least one charge of tax evasion. Earlier this year, we reported the first public display of federal […]

Eli S. Noff, Esq., Partner By now, most Americans with assets abroad understand that the Internal Revenue Service (IRS) expects them to disclose these assets-or risk subjecting themselves to serious penalties for failure to comply. Recently, the IRS has provided significant and welcome relief from reporting requirements for a particular category of assets that were […]

Eli S. Noff, Esq., Partner EXECUTIVE SUMMARY The doctrine of collateral estoppel does not bar the IRS’s pursuit of civil tax liability, even where the same liability was previously resolved in a criminal proceeding. Taxpayers should remember that, depending on the circumstances, the Internal Revenue Service (IRS) may successfully pursue and recoup both civil deficiencies […]

Eli Noff, Esq., Partner Generally, per Internal Revenue Code (IRC) §6751(b)(1), the Internal Revenue Service (IRS) is precluded from assessing a penalty unless the initial determination assessment “is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.” Recently, the Tax […]

Eli Noff, Esq., Partner On December 13, 2019, the Internal Revenue Service (IRS) released proposed regulations which provide guidance for businesses and individuals regarding the tax treatment of charitable fund donations made in exchange for state and local tax (SALT) credits. Additionally, the proposed regulations provided guidance regarding the application of the “quid pro quo” […]

The use of offshore accounts is a point of contention in the media these days. The release of the Paradise Papers and Panama Papers arguably aimed to bring down the reputation of those who used these accounts, but the information may have led to an unforeseen result. Instead of just leading to negative press, the […]

Glen E. Frost, Managing PartnerKaitlyn Loughner, Esq. On January 3, 2013, Switzerland’s oldest bank, Wegelin & Co. (“Wegelin”), pled guilty to assisting U.S. taxpayers in hiding more than $1.2 billion in assets from the Internal Revenue Service (“IRS”). Wegelin is the first foreign bank to plead guilty to U.S. tax evasion charges. In 2009, United […]

On May 5th Glen E. Frost wrote a letter, on behalf of the American Citizens Abroad, to IRS Commissioner John Koskinen in regards to private collection firms based in the United States collecting debts of U.S. taxpayers with foreign addresses. The ACA stands behind the belief that U.S. citizens living overseas should not be subject […]

People with unreported foreign assets on tax returns may benefit from the Offshore Voluntary Disclosure Program or the Streamlined process. U.S. persons who own property or other assets in countries outside the United States may do so in part for potential tax advantages. However, taxpayers may still need to report foreign assets on domestic income […]

By Matthew Tran Effective on July 1st, 2017, the three major credit reporting agencies, TransUnion, Equifax, and Experian, introduced new standards that will require tax liens and civil debts to include more personal information; otherwise, the tax liens and civil debts will be excluded from a person’s credit report. The changes will require tax liens […]