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March 2015

News Briefs


Check out some of my blogs for the month of February! Please click on the links below to read more.


1. US Taxpayers: Beware of these FATCA and Tax Scammers


Tax scams have likely been around for as long as taxes have been collected. In light of the significant penalties, fines, prison sentences and other consequences that can be imposed for tax non-compliance issues, taxpayers have good reason to be apprehensive or nervous if they are contacted by someone claiming to represent the Internal Revenue Service (IRS). Thus, if you are contacted by an IRS agent, it is always prudent to verify their identity, the fact that they are employed by IRS, and request a callback number at the IRS where the agent can be reached. Furthermore, if you are contacted by an individual claiming to represent the IRS or the US government, an experienced tax professional can often more readily recognize the signs of a tax scam. 


Please click here to view the full blog.


2. Have you received a letter from your foreign bank regarding FATCA? 


Since January of 2014, those holding accounts in foreign banks throughout the world have received Foreign Account Tax Compliance Act (FATCA) letters from their financial institutions. These letters are sent to account holders whom the institution believes have a link to the United States that would give rise to tax reporting and payment obligations. These letters will request that the recipient provide information regarding their disclosures, if any, to the Internal Revenue Service (IRS). These disclosures typically include whether certain documents have been filed, including a Report of Foreign Bank and Financial Accounts (FBAR) and a 1040 personal return, and whether the individual has availed himself or herself of the Offshore Voluntary Disclosure Program (OVDP) administered by the IRS to resolve tax compliance problems.


Please click here to view the full blog.



3. Swiss Bank Credit Suisse Pays $2.6 Billion in Penalties for Aiding Americans in Providing False Tax Information


Zurich, Switzerland-based Credit Suisse is the first global banking organization in more than 10 years to plead guilty to a crime. In May 2014, Credit Suisse pleaded guilty to conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other documents with the Internal Revenue Service (IRS). Under terms of the plea deal and other agreements with state and federal agencies, Credit Suisse will pay roughly $2.6 billion in penalties. While prosecutors have obtained guilty pleas from subsidiaries of global banking units, the Credit Suisse guilty plea shows that federal prosecutors are willing and able to pursue even the largest of banking, investing and private asset units.


Please click here to view the full blog.


4. Which is worse? A failure to file penalty or a failure to pay penalty?


US citizens, legal permanent residents, and other covered individuals have an obligation to file and pay taxes on all sources of worldwide income. If an individual does not satisfy his or her filing and payment obligations, he or she may be subject to penalties for a failure to pay taxes, the failure to file taxes, or both.


Please click here to view the full blog.


5. Online Poker Players Beware: Digital Accounts Can Trigger an FBAR obligation


FBAR reporting obligations require a US taxpayer holding $10,000 or more in a foreign financial account, at any moment in time during the tax year, to file a Report of Foreign Bank and Financial Accounts (FBAR). Once this obligation is known, at least in some contexts, the FBAR reporting requirement seems fairly obvious. Funds held in a foreign bank or securities that exceed $10,000 would rather clearly trigger an FBAR filing requirement. However, services provided over the Internet and hybrid services that can be used for multiple purposes can sometimes obscure these distinctions.


Please click here to view the full blog.



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Picture of Dennis N. Brager
Dennis N. Brager, Esq.
Former IRS Senior Trial Attorney
Nationally Recognized California State Bar Certified Tax Specialist

Upcoming Speeches & Webinars

"Offshore Voluntary Disclosure: A Brief Guide to the Various IRS' Programs and Other Ways of Becoming (and Remaining) Tax Compliant"
10:00- 11:30 a.m. PT
March 18, 2015

"Eggshell Audits: Keeping Your Client Out of Jail"
10:00-11:00 a.m. PT
May 6, 2015

"A Brief Guide to Getting (and Keeping) Your Clients with Foreign Connections Out of Trouble, Including FBARs, OVDP, etc.
11:00-11:30 a.m. PT
June 11, 2015

Brager Publications

The Wrap
December 2014

         In the News



"Tax Deductions for Your Addition, Remodel or Accessory Dwelling - Great Design for Aging in Place Can Have Big Tax Benefits!"

New Avenue

February 2015


"US Worldwide Tax Law Forces Americans to Denounce Citizenship - Experts"


February 2015


"Small Business Taxes 2015: Everything You Need to Know"

Business News Daily

January 2015


"Here's How Much Real Housewife Teresa Giudice Could Profit From Prison Sentence"

Yahoo Celebrity

January 2015




Previous Events

Dennis' webinar, "The IRS Collection Process: What You Need to Know to Advise Your Clients" is available on the Brager Tax Law Group Website: 

Click here for the Recording
Click here for the PowerPoint

Dennis' webinar, "Innocent Spouse Relief: Fact or Fiction?" is available on the Brager Tax Law Group Website:
Click here for the Recording 
Click here for the PowerPoint

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 Our Services

The Brager Tax Law Group is a tax litigation and tax controversy law firm, which represents clients with tax problems and tax disputes with the IRS, the California Franchise Tax Board (FTB), the State Board of Equalization (SBE) and the Employment Development Department (EDD). All of the firm's tax lawyers are former trial attorneys with the IRS. 

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Brager Tax Law Group
10880 Wilshire Boulevard
Suite 880
Los Angeles, California 90024
Tel: (310) 208-6200
Fax: (310) 478-8030