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IRS Suspends Most Collection Activities due to COVID-19 Pandemic

Due to the ongoing COVID-19 Pandemic, the IRS has provided relief to taxpayers by extending filing and other deadlines. Now, in an internal memorandum from Fred Schindler the Director of Headquarters Collection (SBSE), the IRS continues to provide relief to taxpayers with tax debt by suspending most tax collection activities.…

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Not Just Another Covid-19 Announcement

Some of you may be concerned about the impact of the Coronavirus aka Covid-19 outbreak on your taxes, and those of your clients. The news from the IRS has been slow in coming. On Friday of last week President Trump declared a National Emergency. At the same time, he directed…

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Don’t Jump at the Chance to go to IRS Appeals Directly from a Tax Audit

In a 2019 U.S. Tax Court case, Palmolive Building Investors, LLC v. Commissioner, 152 T.C. No. 4, (2019) (Palmolive II), the Tax Court held that both penalties determined by the Revenue Agent in a tax audit and additional penalties later determined  by an Appeals Officer in the IRS Independent Office…

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Dennis Brager Published in Fox News Article

Recently, Dennis was interviewed by Fox News on his thoughts on Prince Harry and Meghan Markle’s move to North America and how it may impact their taxes.  Below is an excerpt of the quote: “Basically speaking, the U.S. has a system of taxation which is different from the vast majority…

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Should I Take Advantage of the IRS Offshore Voluntary Disclosure Program?

The IRS Offshore Voluntary Disclosure Program (OVDP) offers taxpayers with unreported income from foreign financial accounts a chance to come into compliance with the law. The program benefits taxpayers by offering lower penalties and eliminating the threat of criminal prosecution for failing to file Foreign Bank Account Reports (FBARs). Failure…

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What Are the Qualifications to File FBARs Under the IRS Streamlined Offshore Reporting Procedure?

The IRS expanded its streamlined filing compliance procedures in 2014 to allow more taxpayers with offshore bank accounts to take advantage of the program. The procedures are now available to some taxpayers living in the United States, as well as many U.S. taxpayers living outside the country. Benefits of Streamlined…

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What is the Exit Tax Charged to Expatriates?

Some taxpayers may be attracted to the idea of expatriating in order to reduce their tax liability, but the “exit tax” that must be paid upon renunciation of citizenship can complicate those plans. This exit tax, also known as the expatriation tax, treats the taxpayer as though he or she…

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