Blog

25
May

Randall Andreozzi Co-Authors Article on FBARS

Individuals with a financial interest in bank accounts or certain foreign financial accounts must report these accounts, if their cumulative value exceeds a threshold amount. Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly known as FBAR, is the form which is used to satisfy this reporting requirement. The FBAR form is required to be filed annually

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5
Mar

We Have Merged Click Here to Find Out the Exciting Details

March 2012, Buffalo,NY– A merger between Buffalo‐based firms Andreozzi Fickess LLP and Bluestein & Weber P.C. has been announced effective March 5, 2012. The merged firm will practice as Andreozzi, Bluestein, Weber, Brown LLP. The new firm’s professionals include former attorneys from Internal Revenue Service, Office of Chief Counsel, former Special Assistant United States Attorneys, and former Internal Revenue Service audit

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13
Apr

HSBC Bank Accounts Targets by IRS Offshore Activity Efforts

On April 7, 2011, a United States District Court issued an order permitting the IRS to serve John Doe summonses requesting information from HSBC Bank regarding U.S. taxpayers who hold HSBC accounts maintained in India. The John Doe summonses were authorized on the basis that the IRS had a reasonable basis to believe that a group or class of persons

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1
Apr

IRS Launches Compliance Initiative on Estate & Gift Tax

The IRS has recently launched a compliance initiative aimed at identifying taxpayers with potential estate or gift tax liabilities or related compliance issues. As part of this initiative, the IRS has requested and received information from state and county authorities in Connecticut, Florida, Hawaii, Nevada, New Hampshire, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia, Washington, and

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11
Feb

IRS Offers New Voluntary Disclosure Program for Offshore Bank Account Holders

On February 8, 2011 IRS Commissioner Douglas Shulman announced a new voluntary disclosure program forU.S. taxpayers with offshore financial accounts. The Offshore Voluntary Disclosure Initiative (OVDI) allows taxpayers with unreported income from offshore financial accounts to properly disclose the income to the IRS in exchange for reduced penalties. The program runs until August 31, 2011. Taxpayers holding an interest in or signature

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11
Jan

WikiLeaks May Impact US Offshore Account Holders

The website, WikiLeaks, has become a controversial news phenomenon. WikiLeaks publishes secret, private, and classified information primarily with respect to government practices. Its recent communication however, brings the impact of its disclosures to the doorsteps of individual citizens. On January 17, WikiLeaks stated that it intends to disclose the foreign bank account information of over 2,000 foreign bank account holders.

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27
Sep

President Obama Signs Small Business Act Providing Significant Tax Benefits

On September 27th President Obama signed the Small Business Jobs Act of 2010  into law. The Act contains several tax provisions that may prove beneficial to many small businesses and their owners. Some of the key provisions are as follows: Temporary exclusion of 100% of the gain realized on the sale of Internal Revenue Code (“IRC”) § 1202 small business stock

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25
May

Government Plans to Subpoena Accountants Engaged in Kovel Arrangements

Attorneys are not always fluent in accounting.  Thus, accountants are often retained by a client’s attorney to assist them in rendering advice to the client.  In the seminal case United States v. Kovel, the Second Circuit Court of Appeals held that communications made by a client to an accountant retained by his attorney will be shielded under the attorney-client privilege. The

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10
Jun

Foreign Bank Account Reporting FBAR and the IRS Voluntary Compliance Initiative of 2009

On March 23, the IRS announced its voluntary compliance initiative to encourage disclosure of foreign bank account details, such as previously undisclosed foreign financial accounts and entities. The policy will remain in place until Sept. 23, 2009. Taxpayers having a financial interest or signature authority over one or more foreign bank accounts worth $10,000 or more should be aware that

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