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Employers, as a matter of course, withhold employment taxes (including Social Security taxes) and income taxes from employees’ pay. These withheld funds are held in trust until the person responsible for paying them makes a federal tax deposit of the funds. In order to ensure these tax deposits are made in a timely fashion, Congress enacted a law providing for a Trust Fund Recovery Penalty (TFRP). This penalty is applied to any person responsible for

U.S. taxpayers seeking to resolve a foreign bank account reporting (FBAR) issue using the IRS’ streamlined procedures must certify, under penalty of perjury, that any failure to report income or accounts or pay taxes as required was “non-willful.” There has been little litigation on the subject of FBAR penalties, and less still on penalties for non-willful, as opposed to willful, failure to file. A recent United States District Court case (James Moore v. U.S. Case

Like and dislike vote If you have signature authority over a foreign financial account, or any financial interest in such an account, you may be required by the Bank Secrecy Act to file a report (FBAR) with the U.S. Department of Treasury if those accounts exceed certain thresholds. Foreign financial accounts include bank accounts, brokerage accounts, mutual funds, trusts, and other accounts. Good News for FBAR Filers First, the good news: a sensible change to

Regular readers of this blog may remember an earlier post discussing foreign bank and financial account reporting requirements (FBAR). That article discussed two voluntary disclosure programs, the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Compliance Procedures program, through which taxpayers may disclose to the United States government any foreign accounts, assets and income they had previously failed to identify. It’s worth going into some additional detail about some differences between streamlined filings and OVDP. The

If you receive stock options as part of your employee compensation package, your company may have provided you with some general tax advice. However, most people require more extensive guidance in order to avoid the tax pitfalls, and seize the tax advantages, that stock options can offer. Stock options can affect you in the current tax year, and far into the future, so it’s important to understand how the taxation of stock options works. To