26 March 2018
Represented numerous individuals with undeclared bank accounts in offshore jurisdictions seeking amnesty under an IRS Voluntary Disclosure Program such as the Offshore Voluntary Disclosure Initiative (OVDI), Offshore Voluntary Disclosure Program (OVDP), Streamlined Domestic Filing Procedure, Streamlined Foreign Offshore Procedure, Delinquent FBAR Submission Procedure and Delinquent International Information Return Submission Procedure.
Negotiated with IRS for a decrease in the civil miscellaneous penalty associated with the Offshore Voluntary Disclosure Program based on partial compliance, alternative statutory framework, etc.
Represented TEFRA Partnership in IRS examination that was settled at the exam level obtaining seven figure penalty relief from the proposed adjustment.
Successfully handled one of the first Taxpayer Advocate appeals out of the 2009 Voluntary Disclosure Program obtaining six figure penalty relief.
Successfully represented an American citizen in an audit with a substantial unreported offshore inheritance, obtaining seven figure penalty relief.
Negotiated the waiver of criminal penalties and a very favorable civil settlement with the IRS for a client who had previously completed a voluntary disclosure without completely disclosing foreign holdings as required under the terms of his closing agreement with the Internal Revenue Service.
Advising a US green card holder with substantial holding abroad who had not properly reported his financial assets on an FBAR or on his FATCA filings through the US streamlined domestic offshore procedures, reducing otherwise applicable tax, interest and penalties significantly.
State of Connecticut, 2004
State of New York, 2005
US Tax Court, 2011
’5 points to consider as overseas disclosure program ends,’ Law360 - May 14, 2018, quoted
‘Tax tips for US expats living in Australia,’ Business Insider Australia - May 8, 2018, quoted
’2017 second highest year on record for US expatriations,’ Withers article - March 26, 2018
‘Its the end of the OVDP world as we know it,’ Withers article - March 26, 2018, co-author
‘IRS to end offshore voluntary disclosure program,’ Think Advisor - March 16, 2018, quoted
‘Offshore voluntary disclosure program shutdown fuels speculation,’ Bloomberg BNA Daily Tax Report - March 15, 2018, quoted
‘Got IP? Get out. For investors thinking of selling, acting in the next few days is critical,’ IPWatchdog - December 22, 2017, co-author
’2017 on track to be banner year for expatriations,’ Bloomberg BNA Daily Tax Report - December 7,2017, co-author
‘Thinking of selling your intellectual property? A few days could make a world of difference to your bottom line,’ __ Withers article - December 6, 2017, co-author
‘Phishing Scams Target Tax Professionals,’ Tax Insider - October 2016 Please click here to read the article on AICPA.
‘The Urgency of FBAR Reporting for US Persons Living in China’, Private Asset Management - August 1, 2016, co-author Please click here to read the article on Private Asset Management
‘IRS Says You Owe Us Money – Bye-Bye US Passport!’, Forbes/Wealth Management - June 23, 2016, co-author Please click here to read the article on WealthManagement.com
‘FBAR Deadline Moves Up 3 Months to April 15’, Accounting Today - August 2015, co-author Please click here to read the article on Accounting
‘IRS Voluntary Disclosure Regime Expands Maximum Penalty Bracket’, Accounting Today - January 2015, co-author Please click here to read the article on Accounting Today
‘Better Not Pout - Like it or Not, US Citizens Owe U.S. Taxes’, Trusts & Estates - December 2014, co-author Please click here to read the article on wealthmanagement.com
‘No Basis for Extending IRS’ Statute of Limitations: Supreme Court Finds an Overstatement of Basis is not an Omission of Gross Income’, Bloomberg BNA - June 2012, co-author Please click here to read the article on bna.com
‘Coming Clean - The US Voluntary Disclosure Initiative in Perspective’, Offshore Investment - April 2011
Connecticut Department of Revenue Services
Zoe’s Best Friend Foundation
Cornell University Alumni Admission Ambassador Network
Connecticut Bar Association
American Bar Association
New York Bar Association
‘Willfulness and the IRS Disclosure Programs: Are You Compliant?’, The Knowledge Group - October 11, 2017, presenter
‘Fully Using Tax Advantages of Limited Liability Companies’, National Business Institute - August 4, 2017, presenter
‘Foreign Account Tax Compliance Act (FATCA)’, Tax All Stars - June 28, 2017
‘Foreign Account Tax Compliance Act (FATCA)’, Surgent McCoy webinar - June 9, 2017
‘Foreign Bank Account Reporting Compliance and Voluntary Disclosure Options’, Surgent McCoy webinar - March 6, 2017
‘Advanced FBAR and FATCA Reporting for Estate and Trust Administrators’, Continuing Legal Education Seminar - June 2016
‘Foreign Bank and Financial Accounts (FBAR)’, Surgent Professional Education - June 9, 2016
‘FATCA filings and FBAR filings’, Edward Jones Tax All Stars, webinar - October 2015
‘FBAR Issues for Beneficiaries, Trusts and Trustees, Estates and Executors’, Continuing Legal Education Seminar - June 2015
‘Foreign Bank and Financial Accounts (FBAR)’, Surgent Monthly Tax Update, webinar - June 9, 2015 To order this webinar, please click here.
‘Foreign Bank Account Reporting Compliance and Voluntary Disclosure Options’, Surgent McCoy, webinar - June 5, 2015
‘US Offshore Voluntary Disclosure Program and Other Options to Address Unreported Income or Assets’, The 20th World Offshore Convention - November 2013
‘Tax Opportunities in Partnership and Disregarded Entity Formation’, Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012
‘Tax Issues and Strategic Planning for Partnership and LLC Contributions’, Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012
‘Partnership and LLC Equity for Service Providers and Other Tax Issues (and Opportunities) Arising from Management Structuring’, Continuing Legal Education Seminar Tax Planning for Domestic Partnerships and Limited Liability Companies - March 2012