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...
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...
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...
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...
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...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
Most amended returns are amendment work. A few are tax-resolution cases that happen to involve a Form 1040-X. Confusing the two is one of the most common procedural mistakes in this practice area, and it usually shows up the same way: the taxpayer files Form 1040-X...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The voluntary-correction-versus-waiting question is a strategic decision, not a moral one. The taxpayer who has discovered a prior-return error has three options: correct it voluntarily through a Form 1040-X, wait and respond if and when the IRS contacts the taxpayer...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
A missed Form 1099-B is one of the most common 1040-X triggers and one of the easiest to handle badly. The IRS receives the 1099-B directly from the broker, runs information matching against the filed return, and surfaces any mismatch through the Automated...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The voluntary-amendment question is one of the most consequential decisions in a tax-resolution matter. It is not “Can I amend?” or “Should I file Form 1040-X?” It is “Given what I now know about a prior return, and given that the IRS has...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
A CP2000 is not a tax bill, not an audit, and not an invitation to file an amended return. It is a proposed change to the filed return based on information matching, with a response form, a deadline, and a defined administrative path that ends in either resolution or...
