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VietnameseContents1 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 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 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 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 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 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 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 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 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 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 Offshore Bank Account & Income Quiet Disclosure turns Criminal2 Quiet Disclosure Criminal Plea3 Golding & Golding: About Our International Tax Law Firm4 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists Offshore Bank Account & Income Quiet Disclosure turns Criminal Offshore Bank Account & […]
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 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 […]