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 24, 2014 4 min read

Streamlined Offshore Voluntary Disclosure Program – Part One
On September 1, 2012, the IRS first offered the streamlined offshore voluntary disclosure ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 4 min read

Quiet Disclosure and IRS Offshore Voluntary Compliance
THE PROCESSES FOR FIXING THE PROBLEM
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Sam Brotman, JD, LLM, MBA August 24, 2014 3 min read

IRS Voluntary Disclosure
Tax professionals, the IRS, and FinCEN have independently and together worked to find ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 7 min read

Streamlined OVDP - Penalties for Not Participating
The Departments of Justice and Treasury have joined forces to crack down on the failure ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 4 min read

Offshore Voluntary Disclosure Introduction - Part Two
The IRS used much of the information it accumulated under the 2009 OVDP to continue ...
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Sam Brotman, JD, LLM, MBA August 24, 2014 4 min read

Offshore Voluntary Disclosure Introduction - Part One
The Department of Treasury and the Department of Justice have a new mandate – stop ...
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