U.S. Taxation of Foreign Mutual Funds (PFIC & Mutual Funds) The IRS Tax Rules involving Foreign Mutual Funds are not…fun. We will provide you a basic summary to regarding Foreign Mutual Funds, including: What is a PFIC? What is Form 8621? What is a MTM Election? What is a QEF Election? What is IRS Offshore Voluntary Disclosure?…
Unfiled Tax Returns – IRS Amnesty | FBAR & FATCA Penalty Waivers
Unfiled Tax Returns – IRS Amnesty | FBAR & FATCA Penalty Waivers If you have unfiled Tax Returns, can you still qualify for OVDP, Streamlined Filing Compliance Procedures, or a Reasonable Cause submission to disclose unreported/undisclosed foreign income, assets, accounts, investments, etc.? The answer is, maybe. Unfiled Tax Returns As an international tax law firm that…
From Temporary Visa to U.S. Resident – Qualify for Streamlined Foreign Offshore?
Despite what some inexperienced Offshore Disclosure Lawyers who are eager to sell you on their services may tell you, not everyone who applies for the Streamlined Voluntary Disclosure Program will qualify for it, and not everyone who submits a Certification Form 14654 or Form 14653 will be accepted. Specifically, the Streamlined Foreign Offshore Procedures can be…
Substantial Presence Test vs. 330 Day Rule (SFOP) – Streamlined Foreign Offshore
This post is designed to be the first in a two-part series Re: Streamlined Foreign Offshore Procedures involving some of the key nuances involved in meeting the requirements as a foreign resident vs. non-resident. Before discussing the ambiguity of the current vs. former U.S. Citizen description in the 14653 (IRS Streamlined Foreign), it is important…
Quiet Disclosure FAQ (2018) – Board Certified Tax Law Specialist Attorney
Quiet Disclosure FAQ – Board Certified Tax Law Specialist Attorney An IRS Quiet Disclosure is never recommended. A Quiet Disclosure involves the following: Having Unreported Foreign Accounts, Assets or Income Learning You Were Supposed to Report Foreign Money Reading about FBAR & FATCA Penalties Taking FBAR & FATCA Penalties out of context Getting Scared, and Amended…