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Author Archives: Andrew Aldridge

Update: IRS approach to the Voluntary Disclosure Program of 2012

In a recent American Bar Association webcast officials from the IRS discussed recent developments in its international tax enforcement activities. Voluntary Compliance Programs Programs during 2009 and 2011 netted the IRS $5 billion.  These programs had fixed time periods for participation.  The current 2012 program currently has no fixed “end date”, but this may at […]

Tips for Taxpayers Who Receive an IRS Notice

Receiving a notice from the Internal Revenue Service is no cause for alarm. Every year the IRS sends millions of letters and notices to taxpayers. In the event one shows up in your mailbox, here are eight things you should know: 1. Don’t panic. Many of these letters can be dealt with very simply. 2. There are […]

FBAR Federal Appeals Court upholds IRS position – Willfulness penalities enforced

Followers of the IRS cases against Americans with undeclared foreign assets have been waiting in anticipation for the federal courts to set the scope of the term ‘willfulness’ as it applies to the imposition of civil penalties to file the Report of Foreign Bank and Financial Accounts or FBAR.  Some guidance has now been provided […]

Switzerland and Japan sign FATCA agreement

Please note STEP has changed the link to this story. Please search the STEP website for more information. Recently, Switzerland and Japan announced they had signed agreements with the US to facilitate the implementation of FATCA reporting by institutions within their respective jurisdictions.  Instead of reporting all client data direct to the IRS, Swiss and […]

Update: Obamacare penalty tax may apply to expats

We have previously commented that the Obamacare penalty tax for failure to obtain medical insurance would not apply to those individuals who were resident overseas.  But there are a number of “costs” (now classified as “taxes” by the Supreme Court) that individuals (and employers) will bear. We will discuss these in a later blog post.  […]

What does Obamacare mean for expats?

There has been substantial press coverage over the last couple of days of the Supreme Court’s decision upholding “Obamacare”. Under the plan, individuals will have to pay a penalty if they fail to carry health insurance for themselves and their dependents. These provisions apply to US citizens and resident aliens. While there exemptions for certain […]

Defense of Marriage Act held unconstitutional

A federal district court in New York (southern district New York) has held that a portion of the Defense of Marriage Act (DOMA) is unconstitutional.   The issue in the case was whether the estate of a decedent would claim the unlimited marital deduction for that portion of the estate passing to a same-sex surviving spouse. […]

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