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This form is for contacting Sheepdog Tax Resolution about their services. No solicitations please.

Willful or Non-Willful: The One Question That Controls Your Whole Case

by Noah Green CPA CFE | Jun 20, 2026 | Americans Abroad

The short version If you are an American living abroad with years of unfiled returns or unfiled foreign bank account reports, there is one question that sits upstream of every other decision in your case: was your failure to file non-willful, or was it willful. That...

Streamlined Foreign vs Domestic: The 330-Day Test That Decides 0 or 5 Percent

by Noah Green CPA CFE | Jun 20, 2026 | Americans Abroad

The short version The IRS Streamlined Filing Compliance Procedures come in two versions, and the gap between them is measured in real dollars. The Streamlined Foreign Offshore Procedures carry no offshore penalty when you qualify. The Streamlined Domestic Offshore...

Years Behind on Filing Abroad: The Streamlined Path Most Expats Don’t Know

by Noah Green CPA CFE | Jun 19, 2026 | Americans Abroad

The short version If you are a US citizen living overseas and you have not filed a US tax return or a foreign bank account report in years, you are not alone, and your situation is very likely fixable. The United States taxes its citizens on worldwide income no matter...

IRS Penalty Abatement: First-Time Abate and Reasonable Cause, Explained

by Noah Green CPA CFE | Jun 17, 2026 | Penalty Relief

The short version The IRS adds penalties to a great many tax bills, but a penalty is not always final. Penalty abatement simply means getting a penalty removed or reduced. There are two main routes. The first is First-Time Abate, an IRS administrative break for...

Criminal vs. Civil Tax Exposure in Unreported Income Cases

by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution

The distinction between criminal and civil tax exposure on an unreported-income matter is rarely the question the taxpayer asks first. The question taxpayers usually ask is “Will I get in trouble if I correct this?” The accurate answer is that the...
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