Rumor has it that the IRS is re-thinking its procedures for processing voluntary disclosure applications. Yeah, the same old topic – people with hidden offshore bank accounts wanting to Come to Jesus. Up to now the early dance steps have been: Written disclosure filed with the local IRS Criminal Investigations unit; Interview by a couple [...]

I’m at the office on a Sunday afternoon, working on a fiercely technical pre-immigration tax plan.  (“How do I become a resident of the United States and not pay tax?” is the question.)  Don’t feel sorry for me, though.  In about 2 hours I’ll be watching a primo Elvis impersonator for free in the park.  [...]

This went out to the subscribers on my email list.  If you want to be on the list, there’s a subscription box in the sidebar.  Sign up.  (The box is on the right under the cartoon.) You’ll get more like this. Jello Shot number 1. Risk Capital gains tax on real estate investments will more [...]

This is a distant early warning to nonresidents with U.S. real estate investments. The warning applies to multi-national corporations as well (businesses that operate in the United States and elsewhere in the world) but I am going to focus on real estate investors here. RISK An proposed change in U.S. tax law may double the [...]

More on this topic — the ongoing effort of the United States government to squeeze UBS and the Swiss government into turning over names of U.S. persons with accounts at UBS. Today’s Tax Notes Today has an article (citation 2009 TNT 129-1) with an overview of the brief filed in Federal Court by the Swiss [...]