The Resource Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy

Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy

Label
Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy
Title
Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy
Creator
Subject
Language
eng
Summary
Taxpayers, as well as many tax practitioners, would be hard-pressed to find other areas of the tax law that are more complex than the special tax regimes and reporting obligations applicable to U.S. persons with foreign holdings or activities. In addition to sheer complexity, the level of penalties for non-compliance with international information return reporting requirements can be quite steep, if not draconian. In some instances, especially when unreported foreign bank accounts are involved or the government asserts that a compliance failure is willful, the total level of penalties that can be imposed can be well in excess of the value of the unreported accounts or assets. This article focuses on helping clients seek relief from these civil penalties and, specifically, when reasonable cause will justify this relief
Citation source
In: Journal of international taxation. - New York. - Vol. 25 (2014),
http://library.link/vocab/creatorName
Marcotte, P. (Jr.)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • penalties
  • tax compliance
  • offshore activity
Label
Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy
Instantiates
Publication
Label
Pain relief from undisclosed offshore holdings : IRS international penalty procedure and strategy
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...