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How Did Moore v. United States Change U.S. Tax Law?

We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and whether income could be taxed before it is “realized.”  The Court avoided this...

ABCast Episode 25 – US Expatriate Tax Planning – Part 2

In ABCast Episode 25 - US Expatriate Tax Planning - Part 2, we pick up the conversation regarding tax and legal issue U.S. expatriates might face and how Allen Barron can help. The discussion turns to real estate matters, and the issue of moving money from the United States to...

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful?  If you have accounts with any Foreign Financial Institutions...