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Josepher on The Tax Gap

Josepher on The Tax Gap. Thursday, May 28, 2015. IT'S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS. Today, nearly six years later, the U.S.’ continued offshore enforcement efforts, and new U.S. tax policies have resulted in a vastly different offshore tax environment as U.S. citizens are finding it difficult not to report offshore assets and income. The Criminal and Civil Components of the OVDPs. After its receipt of the Disclosure Letter, if the information submi...

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Josepher on The Tax Gap | josepheronthetaxgap.blogspot.com Reviews

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Josepher on The Tax Gap. Thursday, May 28, 2015. IT'S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS. Today, nearly six years later, the U.S.’ continued offshore enforcement efforts, and new U.S. tax policies have resulted in a vastly different offshore tax environment as U.S. citizens are finding it difficult not to report offshore assets and income. The Criminal and Civil Components of the OVDPs. After its receipt of the Disclosure Letter, if the information submi...

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Josepher on The Tax Gap | josepheronthetaxgap.blogspot.com Reviews

https://josepheronthetaxgap.blogspot.com

Josepher on The Tax Gap. Thursday, May 28, 2015. IT'S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS. Today, nearly six years later, the U.S.’ continued offshore enforcement efforts, and new U.S. tax policies have resulted in a vastly different offshore tax environment as U.S. citizens are finding it difficult not to report offshore assets and income. The Criminal and Civil Components of the OVDPs. After its receipt of the Disclosure Letter, if the information submi...

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Josepher on The Tax Gap

http://josepheronthetaxgap.blogspot.com/2013/11/shifting-burden-of-proof-in-tax-refund.html

Josepher on The Tax Gap. Thursday, November 14, 2013. Shifting the Burden of Proof in a Tax Refund Case. After a federal district court bench trial, it was determined that the Estate of George Batchelor was entitled to refund of income taxes, plus interest, because the IRS had erroneously determined that Mr. Batchelor had under-reported almost $5.8 million in interest income from an installment sale in the year 2000. Batchelor-Robjohns vs. United States. Or “claim preclusion” from contesting ...Were met ...

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Josepher on The Tax Gap

http://josepheronthetaxgap.blogspot.com/2013/11/doj-settlement-with-jp-morgan-another.html

Josepher on The Tax Gap. Tuesday, November 26, 2013. DOJ Settlement with JP Morgan: Another Federal Financial Gap &More Fines and Penalties/Offshore Account Style Enforcement. Through this $13 billion resolution, we are demanding accountability and requiring remediation from those who helped create a financial storm that devastated millions of Americans,” said Associate Attorney General Tony West. Here are some DOJ comments made in an August 29, 2013 press release regarding a newly announced a program de...

3

Josepher on The Tax Gap: Purpose for "JOTTG" - Welcome

http://josepheronthetaxgap.blogspot.com/2013/11/purpose-for-jotc-welcome.html

Josepher on The Tax Gap. Wednesday, November 13, 2013. Purpose for "JOTTG" - Welcome. In 1989, my late law partner and friend, Marvin Gutter and I decided to limit our federal tax practice to tax controversy matters. Over the years we were never able to carry out that mission of exclusivity. Instead, we bowed to the pressures of our active tax practice taking on the not only tax controversy matters but many tax planning and transactional matters which we could not seem to "turn away.". 4 Tax which is sho...

4

Josepher on The Tax Gap: November 2013

http://josepheronthetaxgap.blogspot.com/2013_11_01_archive.html

Josepher on The Tax Gap. Tuesday, November 26, 2013. DOJ Settlement with JP Morgan: Another Federal Financial Gap &More Fines and Penalties/Offshore Account Style Enforcement. Through this $13 billion resolution, we are demanding accountability and requiring remediation from those who helped create a financial storm that devastated millions of Americans,” said Associate Attorney General Tony West. Here are some DOJ comments made in an August 29, 2013 press release regarding a newly announced a program de...

5

Josepher on The Tax Gap: Closing the Offshore Tax Gap: “John Doe” Summons Upon Citibank NA and Bank of New York Mellon For Identification of Persons Who Transacting Business With Accounts At Swiss Banks–11/7/2013 and 11/12/2013

http://josepheronthetaxgap.blogspot.com/2013/11/closing-offshore-tax-gap-john-doe.html

Josepher on The Tax Gap. Tuesday, November 19, 2013. Closing the Offshore Tax Gap: “John Doe” Summons Upon Citibank NA and Bank of New York Mellon For Identification of Persons Who Transacting Business With Accounts At Swiss Banks–11/7/2013 and 11/12/2013. 1 The summonses must be shown to relate to an investigation of an ascertainable group or class of persons,. 3 The U.S. must establish that the information sought to be obtained from the examination of the records or testimony (and the identitie...On No...

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RESOURCES | Estate, Trust, & Probate Litigation | Gutter Chaves Josepher Rubin Forman Fleisher P.A

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Robert A. Chaves. Norman A. Fleisher. Peter J. Forman. Richard A. Josepher. Lauren A. Klein. Jordan L. Klingsberg. Sean M. Lebowitz. Lawrence (Larry) J. Miller. Jenna G. Rubin. NEWS & PRESS. Tax Tables & Info. PROBATE TRUST & GUARDIANSHIP LITIGATION. TAX CONTROVERSIES & COLLECTIONS. Welcome to Gutter Chaves Josepher Rubin Forman Fleisher Miller P. A. Advising, Protecting and Enhancing Individual, Family and Business Wealth. Welcome to Gutter Chaves Josepher Rubin Forman Fleisher Miller P. A. Some of our ...

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Josepher on The Tax Gap

Josepher on The Tax Gap. Thursday, May 28, 2015. IT'S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS. Today, nearly six years later, the U.S.’ continued offshore enforcement efforts, and new U.S. tax policies have resulted in a vastly different offshore tax environment as U.S. citizens are finding it difficult not to report offshore assets and income. The Criminal and Civil Components of the OVDPs. After its receipt of the Disclosure Letter, if the information submi...

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