March 12, 2014
Pain Relief From Undisclosed Offshore Holdings: IRS International Penalty Procedure and Strategy
- March 12, 2014
- Publication: Journal of International Taxation
- Related Attorneys:
- Related Practice Areas: Tax: Business, Tax: Individual
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 noncompliance 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.
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March 21, 2023
Michelle Chapin’s Article on the Use of Arbitration Causes in Trusts is Published by the MSBA’s Estate & Trust Law Section
Michelle Chapin, a Principal in Paley Rothman’s Estate Planning department, authored an article titled "(Un)Enforceability of Arbitration Clauses in Maryland Trusts" in the MSBA's Estate & Trust Law Section Newsletter Volume 29 Issue 1.
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Sec. Deb Haaland – First Native American in the Cabinet
Sec. Deb Haaland is the first Native American to serve in the President’s cabinet and has been instrumental in bringing attention and action to the horrific incident rate of...
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Paley Rothman shares this library of resources with clients and friends of the firm to help them stay ahead of legal and business developments and trends. Here, you will find helpful tips and tools written by our attorneys and relevant to our areas of practice.
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