Takeaways for Banks from the CFPB’s Recent Consent Order on Garnishment Orders
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Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more
An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
In recognition of the continuing economic hardship caused by the COVID-19 pandemic, the Internal Revenue Service is easing its collection activities to avoid the seizure of bank accounts containing either Economic Impact...more
An entity operating in the U.S. needs a U.S. Federal employer identification numbers (“EIN”) in order to open a bank account in the United States, act as an employer, file a tax return and complete certain other corporate...more
French investments in the U.S. vary largely in terms of scale and nature, but whatever it is a small French startup only creating an even smaller U.S. subsidiary or a large French corporation acquiring and restructuring an...more
My violin was made in 1962 by a luthier named Umberto Lanaro, but it bears the label of Eligio Puccini and says it was made in 1947. Lanaro chose in effect to use Puccini’s identity when making my violin, as Lanaro...more
If an individual or business owes but has not paid federal taxes, the IRS will make efforts to collect these taxes. The IRS will first send a series of notices requesting payment, but if the taxpayer does not respond to the...more
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
Generally, the first criterion for determining whether an individual is subject to probate or to estate or inheritance tax in a state is the individual’s domicile at the time of his or her death. In an increasingly...more
On December 23, 2014, the United States Attorney for the Eastern District of North Carolina filed a Complaint for Forfeiture In Rem seeking to forfeit $107,702.66 belonging to Lyndon McLellan, the owner of L&M Convenient Mart...more
The National Taxpayer Advocate made three specific recommendations to the IRS to try to simplify the process for reporting foreign assets. For several years the National Taxpayer Advocate has complained that the disclosure...more
We previously reported that the Internal Revenue Service had been criticized for its controversial, yet legal, practice of seizing bank accounts when the account holder is suspected of engaging in “structuring.” ...more
Why it matters - In response to recent criticism, the Commissioner of the Internal Revenue Service (IRS) John A. Koskinen announced that the agency will adopt a “common sense” approach in how it handles funds that have...more
Federal law requires that anyone engaged in a trade or business who receives more than $10,000 in U.S. currency is required to file a Form 8300 (available here) with the Internal Revenue Service. Failure to do so can subject...more
Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more
Sections 1471 through 1474 of the U.S. Internal Revenue Code (“FATCA”) generally impose a 30% withholding tax on certain payments to a foreign financial institution (“FFI”) unless the FFI has entered into an agreement with...more