Cases

Certification of ‘Seriously Delinquent Tax Debt’ Does Not Violate Due Process Nor Human Rights

Revocation or Denial of Passport in Case of Certain Unpaid Taxes under §7345 §7345 was enacted as part of the 2015 Fixing America’s...

Late Relief Granted for Late Filing of Entity Selection Form 8832 (Ruling 202111010)

Form 8832, ‘Entity Classification Election’ Eligible foreign and domestic entities use the Form 8832 to elect how it will be classified...

Penalties for Non-willful Violations of FBAR Filings must be Assessed on a Per Form Basis

Kaufmann had 13 foreign accounts in Israel that were not reported on the Form TD F 90-22.1, "Report of Foreign Bank and Financial...

Covered Expatriate Charged with Tax Fraud after Concealing $1B in Assets

Who is a covered expatriate? The IRS expatriation provisions apply to US citizens who have renounced their citizenship and long-term...

A Pilot Living in Thailand does not Qualify for the Foreign Earned Income Exclusion

Who can take the Foreign Earned Income Exclusion? A US taxpayer who has foreign earned income such as salaries, wages, commissions,...