Eligible Deferred Compensation Items & U.S. Expatriation Tax Laws This is a common question we receive from clients re: Expatriation, so we wanted to try to explain it in plain (relatively plain) “English.” When it comes time to expatriation from the U.S. and the relinquishing/renouncement of your U.S. Citizenship or Green Card Status – you…
Is Your IRS Offshore Voluntary Disclosure Confidentiality at Risk?
What is the Attorney-Client Privilege and how does it work in Tax Law? As we approach the thick of tax season, our blog entries get less frequent — but we thought this was a very important topic for our clients around the world who are being misled by other attorneys and firms to take the time…
False Tax Return, Unreported Foreign Income & No FBAR – Jail & Fines
False Tax Return, Unreported Foreign Income & No FBAR – Jail & Fines In late 2018, Israel Birman pled guilty to filing a false tax return. One of the main components of the crime was the failure to report foreign accounts on the FBAR. Specifically, “According to court documents, between 2006 and 2014, Israel Birman…
GILTI (2019) – International Income Tax Law Summary & Examples
GILTI (2019) – International Income Tax Law Summary & Examples GILTI is a perfect example of what is wrong with U.S. tax law. GILTI refers to Global Intangible Low-Taxed Income. But, GILTI is not limited to Intangible or Low-Taxed Income. And, as with FATCA, while the goal is to reduce offshore tax evasion and increase…
How to Report Offshore Accounts & Assets on Your Taxes (2019 Update)
How to Report Offshore Accounts & Assets on Your Taxes (2019 Update) It’s 2019 — where did the time go? As part of your New Year’s Resolution, you decided that this year you are going to get into compliance with the IRS (you were very drunk). You know you have foreign accounts, and you know they…