Yes, you can file FBARs for previous years. The IRS allows late submissions through the Delinquent FBAR Submission Procedures if your failure to file wasn’t willful. Acting promptly and voluntarily often helps …
To file an appeal with the IRS, respond to the letter you received—usually within 30 days—using the correct form and including a written statement of what you disagree with and why. For …
A Notice of Intent to Levy is the IRS’s final warning before seizing your assets to collect unpaid taxes. Under IRC § 6331, the IRS must send this letter—typically Letter 1058 or …
For US persons with foreign financial accounts, understanding and complying with FBAR (Report of Foreign Bank and Financial Accounts) requirements is critical—especially when facing FBAR penalties. U.S. persons with financial interests in …
The Mukhi v Commissioner[1] case is another example of just how severe the penalties are for failing to report certain foreign financial activity timely; in this case, it was the failure to …
That certified letter from the IRS just arrived and your heart sinks. A Notice of Federal Tax Lien represents a serious escalation in the tax collection process, but it doesn’t mean all is lost. …
You just received a substantial gift from your aunt in Italy, or perhaps you’ve inherited property from a grandparent in Germany. While these financial windfalls might seem like purely positive events, they come with …
Taxpayers often have a large number of questions and misconceptions about what happens in an IRS field examination of their individual income tax return. This post provides a summary of the steps …
We are delighted to introduce Hughes Noff Tax Law, LLC—a firm born from a shared vision to provide exceptional tax law services tailored to the unique needs of our clients. As we …
Introduction: In Jenner v. Commissioner, 163 T.C. 7 (Oct. 22, 2024) (link to opinion), the U.S. Tax Court held that the Internal Revenue Service (“IRS”) was under no obligation to provide a …
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