As seen in the Wall Street Journal: David Neufeld Profiled in "New Jersey's Top Rated Lawyers of 2014"
LexisNexis® Martindale-Hubbell®, the company that has long set the standard for lawyer ratings, has published a list of Martindale-Hubbell Top Rated Lawyers who have achieved an AV® Preeminent™ Peer Review Rating, the highest rating in legal ability and ethical standards. To create this list, LexisNexis® Martindale-Hubbell® tapped its comprehensive database of Martindale-Hubbell® Peer Review Ratings™ to identify lawyers who have been rated by their peers to be AV® Preeminent™.
Steve Leimberg's Income Tax Planning Email Newsletter - Archive Message #71
David Neufeld & IRS Amnesty for Certain US Taxpayers with Offshore Income and Assets
“On June 18, 2014 the IRS in IR-2014-73 modified its ‘Streamlined’ program for certain US taxpayers who have failed to properly file tax returns or foreign bank account reports, offering the closest thing to a total amnesty practitioners could have predicted. Those that qualify could find it very beneficial; most significantly the program permits the potential waiver of most or all penalties.
Ultimately the determination of whether it is available to those otherwise qualified is based on whether the IRS decides a taxpayer’s past non-compliance was willful. Depending on how one guesses the Service will come out on that tells taxpayers what they should do; if they feel they can make a good case for non-willfulness they should embark on this new program, but if not then they might consider either entering the Offshore Voluntary Disclosure Program, opting out or doing a ‘quiet disclosure.’
For the right taxpayer the Service has exhibited unusual generosity by waiving most if not all penalties and limiting the liability for past taxes to three years. But a detailed analysis is required to be certain one is the right taxpayer, as a mistake can be terribly costly.”
David Neufeld provides members with important commentary that reviews the benefits of the modified “Streamlined” Offshore Filing Program that the Service recently announced. David’s commentary includes a handy flow chart that explains the program’s eligibility requirements, and is available exclusively to LISI members.
David S. Neufeld is a tax and T&E lawyer in Princeton, NJ. He represents clients throughout the world, doing both planning and controversy work (administrative and Tax Court). David is also an expert witness in civil cases around the country arising from 419 plans. Most notably, David represents the government of the Island of Nevis, for which he has drafted several laws, including the Nevis LLC Ordinance and recent proposed amendments to permit series LLCs and cell captive insurance companies. For more, go to www.DavidNeufeldLaw.com
Here is his commentary: [click on "Read More" to the right]