Representations and warranties are a major part of any business acquisition. In certain purchase agreements, the representations and warranties may be broken…

A “Basket” in a merger or acquisition is generally a minimum amount of damages, almost a deductible that must be reached, in order for an indemnified party to…

As tax attorneys we are often asked about whether a tax debt can be settled with the IRS through an offer in compromise. As part of this question and when we…

Foreign accounts subject to FBAR reporting run from the obvious to less obvious. The most obvious and most common are foreign bank accounts and foreign…

The Streamlined penalty applies to the Streamlined Domestic Offshore Procedures. The penalty is calculated by finding the highest year end balance of the…

Foreign assets may need to be reported to the IRS or FinCEN on either forms 8938, Form 114 FBAR or both. If assets were required to be reported on either, or…

US persons are required to file an FBAR when they control an interest in a foreign financial account and the highest value of those accounts, in aggregate,…

U.S. taxpayers, U.S. citizens and U.S. residents are required to report their worldwide income. Often, taxpayers neglect to include income earned outside the…

Often, US persons who buy real estate in Costa Rica are encouraged to form a Costa Rican company in order to own the real estate. Costa Rican companies are…

Most acquisition agreements such as an asset purchase agreement are going to have representations and warranties made by both or all parties to the agreement…