Publications

2014 OVDP Streamlined / Overview of the 2014 IRS Offshore Voluntary Disclosure Program (OVDP) and Enhanced Streamlined Filing Compliance Procedures

2014 OVDP Streamlined – Alexey Manasuev recently published an article in Tax Notes International highlighting significant changes to the 2012 IRS Offshore Voluntary Disclosure Program…

2014 OVDP Streamlined Update – IRS to Provide Further Guidance on 2014 Offshore Voluntary Disclosure Program (OVDP) and Enhanced Streamlined Filing Compliance Procedures in a Matter of Weeks

Alexey Manasuev attended the 2014 Joint Fall CLE Meeting of the American Bar Association (ABA) Section of Taxation and Section of Real Property, Trust &…

IRS Border Crossing / Delinquent U.S. Taxpayers Under IRS Scrutiny

Lookout! IRS Border Crossing; Delinquent U.S. Taxpayers Are Under IRS and Homeland Security Cross Fire By Alexey Manasuev* Hiding from the Internal Revenue Service (IRS)…

Canadian Foreign Tax Credits and withdrawals from U.S. IRA

In a recent tax ruling, the Canada Revenue Agency (“CRA”) allowed a taxpayer to claim as foreign tax credit a 10 percent income tax surcharge…

Foreign Reporting Penalties

The May 21st edition of the National Post featured an article by Jamie Golombek discussing the harshness of the penalties for late-failing a T1135 Foreign Income Verification Statement;…

Residence Tiebreakers

On August 11, 2010, the National Post posted an article about some of the US tax issues Conrad Black currently faces. The article provides an overview…