Category Archives: International

How Many Months Are There in a Year?

When you were a child you learned that a minute has 60 seconds, an hour has 60 minutes, a day has 24 hours, a month has 28 to 31 days, and that there are 12 months in a year.  Believe … Continue reading

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US-Russia Tax Treaty Mostly Suspended Beginning August 16th

The IRS announced today that based on a request from Russia last August that most of the US-Russia Tax Treaty will be suspended beginning August 16, 2024.  One impact: Russians who have gambling income in the US that’s subject to … Continue reading

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The 2023 Tax Offender of the Year

So many try every year for my award–The Tax Offender of the Year.  It’s not really something to be proud of; after all, to win this award you need to commit really big tax fraud or a series of Bozo-like … Continue reading

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Bozo Tax Tip #8: Use a Foreign Trust to Avoid Taxes!

One of the worst tax schemes in the view of the IRS are offshore (foreign) trusts. In fact, trusts of all sorts—domestic and foreign—are regularly abused. First, not all trusts are bad. Many trusts serve a legitimate purpose, such as … Continue reading

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FBAR Non-Willful Penalty Is Per Report, Not Per Account

Let’s assume you have a non-willful violation of filing the FBAR (Form 114, the Report of Foreign Bank and Financial Accounts).  Is the maximum penalty ($10,000) per account or per report?  The Circuit Courts of Appeal had split on this … Continue reading

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Online Gambling and Cryptocurrency Addresses for 2023

[This list has been superceded by the 2024 list.] If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2022, you must file the Report of Foreign Bank and … Continue reading

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Answering to a Higher Authority

Robert Brockman, the 2020 Tax Offender of the Year, passed away last weekend.  Mr. Brockman was facing a 39-count indictment for tax fraud and related charges; his trial was set for this coming February.  Mr. Brockman’s attorneys argued that he … Continue reading

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When Bad Recordkeeping Helps You (And Bad News for Some Canadian Professional Poker Players)

As we previously reported, the Canada Revenue Agency (CRA) thought that Jonathan Duhamel, the winner of the Main Event of the World Series of Poker (WSOP) in 2010 was a professional gambler, and that he conducted himself as a professional … Continue reading

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Is It One Penalty of $10,000 or Multiple Penalties of $10,000?

Suppose you are a resident of a foreign country–say, Romania–and you have foreign financial accounts.  You need to file the FBAR (Report of Foreign Bank and Financial Accounts) to tell the Financial Crimes Enforcement Network (FINCEN) what foreign accounts you … Continue reading

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Bozo Tax Tip #7: Only Income Earned Outside the United States Is Taxable

A few days ago I was explaining to a client the basics of the US Tax Code: All income is taxable unless Congress exempts it; nothing is deducible unless Congress allows it. That’s the basics. My office is in Las … Continue reading

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