Contents1 Offshore Bank Accounts, Divorce & the IRS2 Typical Example of Offshore Accounts & Divorce3 Family Law & Offshore Accounts4 IRS Offshore Disclosure Aspect5 What Do You Do?6 Offshore Voluntary Disclosure7 Golding & Golding: About Our International Tax Law Firm8 Less than 1% of Tax Attorneys […]
Contents1 Civil Tax Fraud Penalty & the IRS2 What is Civil IRS Tax Fraud?3 Offshore Tax Fraud vs. FBAR Penalties4 Understanding IRS Civil Tax Fraud5 More than Negligence6 Civil Code Section 6663 – Imposition of Fraud Penalty7 Clear and Convincing Evidence8 FBAR Willfulness – Lower Standard […]
Contents1 FBAR Filing for Disregarded Entities2 What is an FBAR (FinCEN 114)?3 Who is a United States Person? 4 Do Disregarded Entities have to file an FBAR?5 What Types of Accounts Must be Reported?6 What if my Disregarded Entity Never Filed an FBAR?7 The IRS Has Ways […]
Contents1 Tax Avoidance vs Tax Evasion2 Case Study Example3 Illegal Offshore Avoidance4 Golding & Golding: About Our International Tax Law Firm Tax Avoidance vs Tax Evasion Tax Evasion vs Tax Avoidance: When it comes to taxes and the IRS, sometimes there is a fine-line between planning […]
  Contents1 IRS Foreign Bank Account Investigations2 5 Examples of IRS Investigations3 FATCA Reporting4 Whistleblowers5 IRS Audits6 IRS Voluntary Disclosure/Amnesty by a 3rd Party7 J-5 & Coinbase Subpoena8 What Can You Do?9 Golding & Golding: About Our International Tax Law Firm IRS Foreign Bank Account Investigations […]
?   Contents1 FBAR 2020 Explained2 FBAR Form3 When is the FBAR Due4 Is the FBAR Hard to File?5 2020 Deadline For Filing6 Instructions 7 FBAR Violation Penalty8 Golding & Golding: About Our International Tax Law Firm FBAR 2020 Explained FBAR 2020: The IRS requirements for submitting […]
Contents1 US Taxation of a Usufruct 2 Naked Ownership & Usufruct3 Usufruct Example4 Rights of the Usufruct5 U.S. Tax of a Usufruct6 Reporting for Naked Ownership & Usufruct7 Golding & Golding: About Our International Tax Law Firm US Taxation of a Usufruct  US Taxation of Usufruct & […]
Contents1 US Taxation of New Zealand Pension Plans2 Pillar 1: New Zealand Superannuation3 Pillar 2 Occupational Pension (KiwiSaver)4 How is the KiwiSaver Invested?5 Voluntary (Personal)6 U.S. New ZealandTax Treaty (Article 18 Pension)7 NZ Pension Distributions8 Are NZ Pension Contributions Deductible?9 FBAR, FATCA, 3520 & 8621 New […]
Contents1 U.S. Tax of Foreign Income Explained2 U.S. Citizen or U.S. Person?3 Reporting Foreign Income4 Offshore Reporting Requirements5 Golding & Golding: About Our International Tax Law Firm6 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists U.S. Tax of Foreign Income Explained U.S. Tax of […]
Contents1 Are Italy Pension Plans Taxable in the US2 Reporting on FBAR, FATCA, 3520, and 86213 Pillar 1 (Social Assistance)4 Pillar 2 (Occupational Pensions)5 Pillar 3 (Private Pensions)6 U.S. Italy Tax Treaty (Article 18 Pension)7 Pension Distributions8 Pension Contribution Deductible for US Tax9 FBAR, FATCA, 3520 […]
  Contents1 FBAR Penalties & the IRS2 IRS Offshore Enforcement3 How does the IRS Penalize You?4 Civil Penalty Violations (31 U.S.C. 5321 et seq.)5 Criminal Penalty Violations (31 CFR 103.59)6 Avoiding & Minimize FBAR Penalties7 Golding & Golding: About Our International Tax Law Firm FBAR Penalties […]
Contents1 FBAR & FATCA 2 Case Study Example3 Passport Revocation, Customs Holds & Loss of Green Card4 The IRS Special Agents Also want to Investigate5 Golding & Golding: About Our International Tax Law Firm FBAR & FATCA FBAR & FATCA: When it comes to International Tax, the IRS […]
Contents1 FBAR Investigations2 What is an FBAR Investigation?3 Example of an FBAR Investigation4 The Tax Professional Knows Less Than Michael5 The CPA Learns About Foreign Account Reporting6 Michael is Audited/Under IRS Examination7 The IRS’ IDR is for ALL Income and Accounts8 Golding & Golding: About Our […]
Contents1 Singapore FBAR Penalty Case & Willfulness2 US v. Ho and Tay (Case No. 3:20-cv-3818)3 Defendant had an Accounting Background4 “No” on Schedule B5 Misrepresentation During an IRS Audit6 Willfulness & FBAR7 Golding & Golding: About Our International Tax Law Firm8 Less than 1% of Tax […]
Contents1 Offshore Compliance2 IRS Offshore Compliance in 20203 5 Common International IRS Forms You May Have to File4 What if I am Out of FBAR Compliance?5 What Should You Do?6 Golding & Golding: About Our International Tax Law Firm7 Less than 1% of Tax Attorneys Nationwide […]
Contents1 Offshore Accounts 2 IRS Offshore Compliance3 What is an Offshore Account?4 What if I do Not Report Offshore Accounts?5 Case Study Example — Offshore Account Ownership6 Offshore Account Tax Planning7 Big CPA firms & “Individual” Tax Returns8 Cross-Section of Michelle’s Offshore Tax Situation9 Australian Rental Properties 10 […]
  Contents1 IRS Delinquent FBAR Submission Procedures2 Late FBAR Filing Procedures3 How Many Years Delinquent Can You File?4 What are the Penalties for Delinquent FBAR Filing?5 Golding & Golding: About our International Tax Law Firm IRS Delinquent FBAR Submission Procedures Delinquent FBAR Submission Procedures: The IRS […]
  Contents1 Voluntary Disclosure Tax Amnesty2 What are the Different Types of Amnesty Programs3 Domestic Voluntary Disclosure Tax Amnesty4 Offshore Voluntary Disclosure Tax Amnesty5 Golding & Golding: About our International Tax Law Firm Voluntary Disclosure Tax Amnesty Voluntary Disclosure Tax Amnesty: There are several Voluntary Disclosure […]
Contents1 FATCA Amnesty2 Amnesty Reduces FATCA Foreign Asset Penalties 3 Foreign Account Tax Compliance Act4 What is a FATCA Letter?5 FATCA Filing6 What is included in the 8938 Form?7 What if the Form is not Filed?8 What are the 8938 Penalties?9 Additional Offshore Violation Penalties10 Golding & […]
  Contents1 FBAR Violation & IRS Penalties2 Statute of Limitations3 Foreign Account Investigations are on the Rise4 FBAR Violation Penalties5 Willful & Non-Willful Violations6 Reasonable Cause 7 Additional Offshore Violation Penalties8 Golding & Golding: About Our International Tax Law Firm9 Less than 1% of Tax Attorneys Nationwide […]
Contents1 PFIC Tax & Reporting2 Passive Foreign Investment Companies3 Taxation and Reporting 4 Tax Rules5 What if I Never Reported the PFIC or Paid U.S. Tax?6 Golding & Golding: About Our International Tax Law Firm7 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists PFIC Tax […]
Contents1 FATCA Summary2 FATCA FAQ3 Golding & Golding: About Our International Tax Law Firm FATCA Summary FATCA Summary: FATCA is the Foreign Account Tax Compliance Act. There are more than 110 FATCA Agreements and more than 300,000 reporting FFIs. There are different versions of the agreements, […]
Contents1 Employee Provident Fund (EPF) & US Tax2 Indian Pension System 3 Employee Provident Fund (EPF) & US Tax4 Tax Treaty Article 20 & EPF5 Other Types of Indian Pension6 Indian Social Security & U.S. Tax7 Article 20 (2)8 Golding & Golding: About Our International Tax Law […]
Contents1 US Taxation of Canadian Pension Plans2 Pillar 1 Canadian Government3 Pillar 2 Employment Pension4 Pillar 3 Individual/Personal Pension5 RRSP Under the US/Canada Tax Treaty6 Deducting RRSP Payments on a U.S. Tax Return7 Form 8891 8 RRIF (Registered Retirement Investment Fund)9 TFSA (Tax Free Savings Account)10 Golding […]
Contents1 US Tax of Swiss Pension Plan Income2 Swiss Pension System3 1st Pillar: OASI (Old Age and Survivor’s Insurance) 4 Swiss & US Tax Treaty Analysis5 2nd Pillar: Occupational Pension6 3rd Pillar: Private Pension7 Golding & Golding: About Our International Tax Law Firm8 Less than 1% of […]
Contents1 Reporting Swiss Numbered Accounts in US2 Swiss Numbered Accounts are Dangerous3 How Does IRS Find Your Swiss Numbered Account?4 Deferred Prosecutions and Swiss Numbered Accounts5 What if I am Out of Offshore Compliance?6 What Should You Do?7 Golding & Golding: About Our International Tax Law […]
Contents1 IRS Form 3520-A Penalty2 What is the Form 3520-A Penalty?3 Summarizing IRS Form 3520-A Penalty4 Form 3520-A Reasonable Cause5 Golding & Golding: About Our International Tax Law Firm6 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists IRS Form 3520-A Penalty The 3520-A form […]
Contents1 Eighth Amendment FBAR Penalty Defense2 What is the 8th Amendment3 What are FBAR Penalties?4 8th Amendment Violation Against Mr. Schwarzbaum5 Golding & Golding: About Our International Tax Law Firm6 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists Eighth Amendment FBAR Penalty Defense 8th […]
Contents1 Russian Businessman Accused of Expatriation Tax Fraud 2 U.S. v. Oleg Tinkov3 Department of Justice Press Release4 Golding & Golding: About Our International Tax Law Firm5 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists Russian Businessman Accused of Expatriation Tax Fraud  Russian Businessman Accused […]
Contents1 Is a Self-Managed Superannuation Fund (SMSF) Taxed in the US?2 Form 3520-A & Self-Managed Superannuation Fund (SMSF)3 Rev Proc 2020-17 & Self-Managed Superannuation Fund4 Taxation of Self-Managed Superannuation Fund5 Golding & Golding: About Our International Tax Law Firm Is a Self-Managed Superannuation Fund (SMSF) Taxed […]
Contents1 Eggshell Tax Audit2 Eggshell Audit Increases Risk of IRS Penalties 3 Golding & Golding: About our International Tax Law Firm Eggshell Tax Audit Eggshell Audit: Certain tax examinations by the IRS result in a high risk of penalties and even criminal exposure. In this type of […]
Contents1 Report Foreign Pension on IRS Form 3520-A?2 Form 3520-A & Foreign Pensions3 The Basics of Which Foreign Trusts are Reportable4 RRSPs and the Form 3520-A5 What Does Rev Proc 2014-55 provide?6 Canadian Retirement vs. Other Countries7 Rev Proc 2020-17 Further Limits 3520-A Reporting8 Not Qualified […]
  Contents1 402(b) Foreign Pension Plans & the IRS2 Foreign Pension Employment Trusts3 IRC 401 and 4024 Summary of 401/402 Employment Trusts5 Can a Foreign Pension be “Qualified”?6 Analysis of Foreign Pension and 401, 402 and 5017 Potential Tax Consequences of Foreign Pension8 Treatment as Social […]
  Contents1 Quiet Disclosure Risk2 10 Reasons to Avoid Illegally Disclosure of Assets3 IRS Enforcement of Offshore Penalties4 Statute of Limitations5 Golding & Golding: About Our International Tax Law Firm Quiet Disclosure Risk Quiet Disclosure IRS: When a U.S. person has unreported offshore income or accounts, […]
  Contents1 Pre-Immigration Tax Planning Basics2 5 Pre-Immigration Tax Planning Considerations3 Plan Before Green Card or Citizenship4 Substantial Presence is not Just For Work-Visas5 Green Card Ramifications6 Exit Strategy7 Worldwide Asset Reporting FATCA, FBAR, 35208 Golding & Golding: About our International Tax Law Firm9 Interested in […]
Contents1 Spanish Pension Plan U.S. Tax Rules2 Pension Plan System in Spain3 Spain & US Tax Treaty Analysis4 2nd Pillar: Occupational Pension5 3rd Pillar: Private Pension6 Form 8833 For Pension in Spain7 Golding & Golding: About Our International Tax Law Firm8 Less than 1% of Tax […]
Contents1 Hapoalim and DOJ Deferred Prosecution Agreement2 Hapoalim Deferred Prosecution Agreement3 DOJ Press Release4 Golding & Golding: About Our International Tax Law Firm Hapoalim and DOJ Deferred Prosecution Agreement Bank Hapoalim Succumbs to $874 Million Dollar DOJ Penalty: When keeping it real goes wrong, right? The […]
Contents1 Who does the United States Exchange Tax Information With?2 What is a TIEA?3 U.S. Taxpayers at Risk4 Sample Tax Information Exchange Agreement Language5 United States TIEA and DTA List6 Golding & Golding: About Our International Tax Law Firm7 Less than 1% of Tax Attorneys Nationwide […]
Contents1 FBAR Penalty for Deceased Extends to Personal Representative 2 U.S v. Sitt (Case 1:20-cv-21672-XXXX)3 What is Section 5314?4 Obligation to Report Interest in Foreign Accounts5 U.S. Alleges Willful FBAR Violations6 Personal Representative vs. Estate7 Estate FBAR Liability8 Personal Representative FBAR Liability9 Why are FBAR Penalties against […]
Contents1 Exit Tax for Green Card Holders2 How is “8 of the last 15 years” calculated?3 Form 8854 — Long-Term Resident (LTR)4 When Does Residence for A Green-Card Holder Begin5 When does the Status End?6 Example7 Golding & Golding: About Our International Tax Law Firm Exit […]
Contents1 Treaty Based Return for Superannuation as Social Security2 Form 8833 Tax Treaty Position for Superannuation3 Treating a Super as Social Security Exempt from U.S. Tax4 Superannuation as Exempt Social Security5 8-Step Roadmap of the Analysis6 Foreign Pension Tax Treaty Positions7 U.S. Tax on Super  Contributions […]
Contents1 US Tax of Singapore CPF, Assets, & Income2 CPF (Central Provident Fund)3 CPF & U.S. Tax4 CPF FBAR & FATCA Reporting5 We Specialize in Safely Disclosing Foreign Money6 Golding & Golding: About Our International Tax Law Firm US Tax of Singapore CPF, Assets, & Income […]
Contents1 Superannuation, Form 3520-A & Rev Proc. 2020-17 2 Report The Super on Form 3520 and 3520-A3 Relying on Rev. Proc 2020-17 to Not Report4 Eligible Individual5 Is a Superannuation a Tax Favored Retirement Trust?6 The Key Point of the Analysis7 Golding & Golding: About Our International […]
Contents1 Avoid FBAR & FATCA by Closing an Offshore Bank Account?2 Timing the Account Closing Example3 Closing an Account to Avoid Past FBAR & FATCA Reporting4 Golding & Golding: About Our International Tax Law Firm Avoid FBAR & FATCA by Closing an Offshore Bank Account? Avoid […]
  Contents1 Reporting Foreign Income2 How to Report Overseas Income to the IRS3 IRS Form 1040 Foreign Income Basics4 Additional Foreign or Offshore Reporting5 What Can You Do?6 Golding & Golding: About Our International Tax Law Firm7 Less than 1% of Tax Attorneys Nationwide Are Certified […]
Contents1 FBAR Audit Triggers2 What Triggers a Foreign Bank Account Audit?3 Golding & Golding: About Our International Tax Law Firm FBAR Audit Triggers When a U.S. person has foreign accounts, they may have to file an FBAR. The failure to file a timely or accurate FBAR […]
Contents1 Confidentiality & Attorney-Client Privilege in Tax Return Preparation 2 No Attorney-Client Privilege with a 3rd Party CPA 3 Golding & Golding: About Our International Tax Law Firm4 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists Confidentiality & Attorney-Client Privilege in Tax Return Preparation  Attorney-Client Privilege […]
  Contents1 IRS Streamlined Filing Compliance Procedures (SFCP)2 Purpose of the Streamlined Program3 What is Willful or Non-Willful?4 Non-Willfulness is Required5 Golding & Golding: About Our International Tax Law Firm IRS Streamlined Filing Compliance Procedures (SFCP) Streamlined Filing Compliance Procedures (SFCP): The IRS Streamlined Procedures are […]
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