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The Structure of a Business Contract Guides a Successful Business Transaction

The structure of a business contract has a substantial impact on the quality of the transaction, and the likelihood of a successful outcome.  A well drafted business contract clearly establishes the role of each party, the goods and/or services to be exchanged and the value of the contract.  Contracts that...

Why Should US Taxpayers With Offshore Accounts and Assets Be Cautious When Considering the Streamlined Domestic Offshore Procedures?

Why shouldn't every US taxpayer with offshore accounts or assets choose the Streamlined Domestic Offshore Procedures when coming into compliance with the IRS and FBAR reporting requirements under FATCA?  Why wouldn't a US taxpayer simply want to claim "non-willful" conduct in their disclosures of offshore bank accounts, investments and assets...

Quiet FBAR Disclosures Are Not What the IRS is Looking For

The IRS has been quite clear in recent publications that a "quiet" disclosure of offshore bank accounts and assets not previously reported on appropriate FBAR or Form 8938 is not enough to come into compliance.  The OVDP is the option that presents the least risk to US taxpayers. The two...