News & Events

March 12, 2014

Pain Relief From Undisclosed Offshore Holdings: IRS International Penalty Procedure and Strategy

Taxpayers, as well as many tax practitioners, would be hard-pressed to find other areas of the tax law that are more complex than the special tax regimes and reporting obligations applicable to U.S. persons with foreign holdings or activities.

In addition to sheer complexity, the level of penalties for noncompliance with international information return reporting requirements can be quite steep, if not draconian. In some instances, especially when unreported foreign bank accounts are involved or the government asserts that a compliance failure is willful, the total level of penalties that can be imposed can be well in excess of the value of the unreported accounts or assets. This article focuses on helping clients seek relief from these civil penalties and, specifically, when reasonable cause will justify this relief.

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News

November 19, 2020

Six Attorneys Named “Top Lawyers” by Washingtonian Magazine - December 2020 Issue

Paula Calimafde, Michelle Chapin, Tracey Coates, Deborah Cohn, Glenn Cooper and Eva Juncker were all selected to Washingtonian's Top Lawyers list for 2020.

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Blog

The Clock is Ticking Again on Lawsuits

The COVID-19 pandemic has disrupted “business as usual” in many ways. People and businesses have been focusing on safety measures and efforts to maintain financial...

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Resource Center

Paley Rothman shares this library of resources with clients and friends of the firm to help them stay ahead of legal and business developments and trends. Here, you will find helpful tips and tools written by our attorneys and relevant to our areas of practice.

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