If you have more questions about foreign inheritance or need guidance with other international tax matters, call 410-671-0741 to schedule a confidential consultation with a Frost Law international tax attorney.

An FBAR must be filed electronically; this can be done through the Financial Crimes Enforcement Network’s BSA E-Filing System. If you are an individual, simply select the “no registration option,” to fulfill your filing obligation. Institutions however must register for the BSA E-Filing System in order to File FBAR. If you would like to paper-file […]

Peter Palsen, International Tax Professional In the 2018 book Red Card – How the U.S. Blew the Whistle on the World’s Biggest Sports Scandal, author Ken Bensinger spends 368 pages discussing how the Internal Revenue Services (IRS), Treasury Financial Crimes Enforcement Network (FinCEN) and the Federal Bureau of Investigation (FBI) collectively carried out a cross-border, […]

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 […]