Sam Brotman, JD, LLM, MBA June 24, 2020 79 min read

The Complete Guide to International Tax Compliance

Under the law, U.S. citizens, resident aliens and certain nonresident aliens are required to report worldwide income from all ...

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Sam Brotman, JD, LLM, MBA August 25, 2014 4 min read

Opting Out of the Offshore Voluntary Disclosure Program (ODVP) - Part Two

Here are the steps that IRS examiners take before a taxpayer makes the irrevocable ...
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Brotman Law August 24, 2014 6 min read

Delinquent FBAR Submission Procedures

Some taxpayers may not need to use the Offshore Voluntary Disclosure Program or the ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 4 min read

Opting out of the Offshore Voluntary Disclosure Program - Part One

Opting out of the offshore voluntary disclosure program can be a difficult choice. An opt ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 6 min read

The OVDP Process – Part Four

Example of the Penalty Structure in the OVDP Process The Criminal Investigative unit is ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 3 min read

The Offshore Voluntary Disclosure Process – Part Three

Offshore Voluntary Disclosure - Interview with your examiner
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Sam Brotman, JD, LLM, MBA August 24, 2014 5 min read

The OVDI Process – Part Two

The OVDI Process - After Preclearance is received If a taxpayer makes all the requisite ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 5 min read

The Offshore Voluntary Disclosure Process – Part One

The precise procedures under the Offshore Voluntary Disclosure process are murky at best. ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 7 min read

Streamlined Voluntary Disclosure for Non-Residents

Eligibility: In order for non-residents U.S. taxpayers to be eligible to participate in ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 4 min read

Streamlined Offshore Voluntary Disclosure Penalties

A Summary of the Streamlined Offshore Voluntary Disclosure Penalties The Title 26 ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 3 min read

Streamlined Voluntary Disclosure Eligibility

Streamlined Voluntary Disclosure Eligibility Requirements In addition to having to meet ...
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