by Michele Weiss | Apr 4, 2023 | FBAR, Internal Revenue Service, Offshore Income
Michele Weiss, Principal at Holtz, Slavett & Drabkin, will participate in a Beverly Hills Bar Association panel exploring how to navigate the new landscape for Foreign Bank Account Report (FBAR) penalties in light of the U.S. Supreme Court decision in Bittner v.... by David J. Warner | Jun 22, 2022 | FBAR, Internal Revenue Service, Offshore Income
On June 21, 2022, the U.S. Supreme Court decided to review (that is, granted certiorari) in the case of Bittner v. United States. This case centers around the report of foreign bank and financial accounts (FBAR) and penalties for not timely filing the FBAR form. The... 
by Michele Weiss | Mar 22, 2022 | FBAR, Internal Revenue Service, Offshore Income
by Michele Weiss US taxpayers are obligated to file a foreign bank account report (“FBAR”) if the aggregate value of their foreign account interests exceeds $10,000 on any day during a calendar year. 31 U.S.C. § 5314; 31 C.F.R. §§ 1010.350(a), 1010.306(c). Taxpayers... 
by Igor Drabkin | Aug 31, 2020 | Audit, FBAR, Internal Revenue Service, Offshore Income, Tax Litigation, Uncategorized
Crackdown on the offshore accounts continues to be one of the top priority issues for the IRS. In the last few years, the DOJ and the IRS have taken aggressive positions in imposing and collecting huge penalties for taxpayers’ failure to report their foreign accounts... 
by Gary Slavett | Mar 25, 2020 | Audit, COVID-19, Criminal Tax, Employment Tax, Exempt Organizations, FBAR, Innocent Spouse Relief, Internal Revenue Service, Offshore Income, Tax Collection, Tax Litigation, Trust Fund Recovery Penalty
To help people facing the challenges of COVID-19 issues, the Internal Revenue Service announced a series of steps to assist taxpayers by providing relief on a variety of issues ranging from easing payment guidelines to postponing compliance actions. Holtz, Slavett... 
by Igor Drabkin | Mar 6, 2020 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
On March 5, 2020, the U.S. Department of Justice unsealed an indictment, charging a Russian-born billionaire Oleg Tinkov with filing false U.S. tax returns. Tinkov, who held U.S. citizenship, was the indirect majority shareholder of an online bank (TCS) that provided...