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Month: October 2012

New Tax Planning Opportunities for High Income Individuals

30 October, 2012

To help appreciate the planning opportunities individuals may have between now and year end, we have prepared a summary of the key tax law provisions affecting high income individuals. Tax Provisions Which May Impact Planning

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Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities

26 October, 2012

Unless Congress acts quickly, taxes are going up!  Although major tax law changes are set to take place in 2013, uncertainty makes it hard for families and businesses alike to plan ahead. Below are the expected

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2012 Offshore Account Criminal Tax Cases

19 October, 2012

The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance

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IRS Notices for OVDI Program

12 October, 2012

When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of the 2009 OVDP, the IRS

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Top 10 factors to consider before deciding to opt out of OVDI or OVDP

9 October, 2012

While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible

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Recent Posts

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  • Kwong: Preserving Client Claims for COVID-Era Penalty and Interest RefundsMay 13, 2026
  • Internal Revenue Service’s Clarification on Reasonable Cause for Form 5472 PenaltiesMay 12, 2026
  • Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This JuneMay 9, 2026

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  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471

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