Discovered Your Spouse’s Offshore Accounts – A Double-Edged Sword

Offshore Accounts & Divorce – IRS Disclosure vs. Settlement Leverage A long time ago, I used to clerk for a former Chief Judge for all the General Courts in Virginia State and his #1 advice to me in the practice of law: always aim before firing. This is never more true than in situations involving Offshore Accounts and divorce….


High Tax Kick Out (HTKO) – IRS Reduction in the Foreign Tax Credit

The High-Tax Kick-Out (HTKO) is just a…bummer. Essentially, in a HTKO scenario, the IRS penalizes individuals who paid too much in Foreign Taxes, by limiting the application of the Foreign Tax Credit involving passive related activities, and instead re-categorizing the credit to the General Income category. Since it is a very complicated topic, the key…


Out of Tax Compliance to both the U.S. & Foreign Tax Authorities?

Out of Tax Compliance to both the U.S. & Foreign Tax Authorities? Being out of tax compliance to both the IRS and foreign tax authorities for unreported accounts and income is not uncommon, and you are not alone. We can help you get into compliance. U.S. & Foreign Tax Non-Compliance  It is very common for individuals…


IRS Special Agent – IRS Offshore Money | 3 Examples of Whistleblowing

IRS Special Agent – 3 Examples of How the IRS Finds your Offshore Money. IRS Special Agents The IRS Special Agents are specially trained IRS Agents who typically focus their investigations on Criminal Tax related issues. And, with Offshore Tax issues remaining an IRS Top Enforcement Priority, it is important to understand what to do…


Form 8621 Instructions – Summarizing The Basics to IRS Reporting

IRS Form 8621 Instructions are a tough nut to crack (so you can just imagine the difficulty in preparing the actual form). The 8621 form is technically called “Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund” and is used in situations in which a person has a PFIC (Passive…