201804.09
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IRS Investigates Foreign Assets & Accounts – Certified Tax Specialist

IRS Investigates Foreign Assets & Accounts – Certified Tax Specialist For many years, individuals, businesses and estates that knowingly or recklessly (aka willfully) evaded paying tax on foreign income, or did not report foreign accounts, assets, or investments to the IRS had a get out of jail free card – OVDP. IRS Investigates Foreign Assets & Accounts…

201804.06
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International Tax Implications of Divorce (2018) – IRS Penalty Risks

International Tax Implications of Divorce (2018) – IRS Penalty Risks When spouses divorce, and assets include offshore or foreign accounts, investments, or other income from abroad — there are various tax, and penalty implications to be aware of. International Tax Divorce During our many years of practice, we have come across several instances where one…

201804.04
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PFIC Distributions – First Year vs. First Distribution (Tax Specialist)

PFIC Distributions – First Year vs. First Distribution (Certified Tax Specialist) PFIC is an acronym for “Passive Foreign Investment Company.” As far as tax reporting goes, a PFIC is one of the more complicated aspects of international tax. Mainly, because the term PFIC is very nebulous and not properly defined. Moreover, it is very encompassing,…

201804.02
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Increased Risk of IRS International Tax Prosecution & Penalties (2018)

Increased Risk of IRS International Tax Prosecution & Penalties (2018) In the last year, much has happened with international tax law and the IRS. First, the IRS developed more than 20 new tax enforcement groups — many of which were designed exclusively to curtail tax fraud, tax evasion and money laundering of international money. In addition, the IRS set…