Contents1 Considerations Before Expatriating from the United States2 Are You Already a Dual-Citizen?3 Do You Have a Foreign Passport?4 Are You a Long-Term LPR?5 Are You Five (5) Years Tax Compliant?6 Are You a Covered Expatriate?7 Do You Have Exit Tax?8 Do You Plan on Giving […]
Contents1 Is Your Hourly CPA Ripping You Off on International Tax Prep?2 Get an Estimate Beforehand3 Review Billings Along the Way4 Will They Fix Their Mistakes for Free?5 Will They Refund Hours for Incorrect Work?6 Did You Miss Reporting in Prior Years?7 Current Year vs. Prior […]
Contents1 Can Expats Amend Prior Tax Returns or File Late Taxes Safely?2 Tax Returns and International Reporting3 Is The Taxpayer Non-Willful?4 Are There Unreported Accounts or Assets (Streamlined)?5 Are there No Unreported Assets? (Reasonable Cause)6 Can the Expat File a 1040NR with 8840/8843?7 Can the Expat […]
Contents1 International Information Return (IIR) Tax Penalties2 International Information Return (IIR) Assessable Penalties 3 It is Almost Never Criminal4 You Are (Most Likely) Not Going to Jail5 You Can Protest the Penalty6 Appeal or CDP7 Appeal and/or Court Litigation8 Farhy Case9 Late Filing Penalties May be […]
Contents1 Unrealized Income from a Foreign Corporation and U.S. Taxes2 Subpart F Income3 PFIC MTM Election4 GILTI5 Section 965 as Written Should be Eliminated6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs […]
Contents1 Is Foreign Pension Reported on FBAR, Form 8938, 8621 & 3520-A?2 Who is Considered a US Person for Foreign Pension Reporting?3 Treaties are Mainly for Tax, Not Reporting 4 International Reporting Form Requirements for Foreign Pension5 FBAR & Foreign Pension Plans6 Form 8938 (FATCA) & Foreign […]
Contents1 Did You Receive a Foreign Form Penalty Notice from the IRS?2 2023 Update re: Covid3 What are Automatically Assessed Penalties?4 With Penalty Abatement, Timing is Everything5 Abating the Penalties is About Strategy6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year […]
Contents1 Avoiding Double Taxation When Living Abroad2 Worldwide Income for Individuals3 Foreign Earned Income (and Housing) Exclusion4 Foreign Tax Credits5 Treaty Election6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Need […]
Contents1 Validity of Section 965 Repatriation Taxes Goes to Supreme Court2 Sixteenth Amendment3 26 U.S.C. Section 9654 How Does the Transition Tax/Mandatory Repatriation Tax Law Work?5 What is Subpart F Income?6 Why Was Subpart F Income Created?7 Example of a Common Section 965 Case8 How Will […]
Contents1 Reporting Foreign Real Estate to the IRS2 Foreign Property Has US Tax & Reporting Implications3 Foreign Rental Income is Reportable4 Depreciation Foreign Real Estate in the U.S.5 Selling Foreign Real Estate is Taxable (Capital Gains) 6 Foreign Real Estate & Expatriating From the US7 Overseas Real […]
Contents1 International Tax Filing Mistakes2 Who is Subject to Worldwide Income Taxation?3 What if the Taxpayer Already Paid Taxes Abroad?4 Foreign Tax Credits: Gross vs. Net5 Foreign Earned Income Exclusion6 Treaty Election7 Real Estate Gross vs. Net Income8 Filing International Reporting Forms if No Tax Return […]
Contents1 Are Overseas Money Transfers to the U.S. Taxable?2 Transfers of Foreign Gift Money 3 Foreign Wire Transfer of Your Own Money to the U.S.4 Late Filing Penalties May be Reduced or Avoided5 Current Year vs. Prior Year Non-Compliance 6 Avoid False Offshore Disclosure Submissions (Willful vs […]
Contents1 Foreign Inheritance Tax 2 Is There a Foreign Inheritance Tax?3 Why Is There No U.S. Tax on Foreign Inheritance?4 U.S. Situs Changes the Foreign Inheritance Tax Rules5 Inheriting Foreign Assets6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid […]
Contents1 Foreign Inheritance Form 3520 Reporting2 Foreign Inheritance Form 35203 U.S. Situs4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 Golding & Golding: About Our International Tax Law Firm Foreign Inheritance […]
Contents1 Foreign Assessable Penalties2 No Pre-Assessment Review3 Delinquent International Information Return Submission Procedures (DIIRSP)4 Farhy (U.S. Tax Court 2023)5 What Can Taxpayers Do at this Time?6 Current Year vs. Prior Year Non-Compliance 7 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)8 Need Help Finding an Experienced […]
Contents1 Form 3520 and Penalties2 Section 6039F3 Notice 97–34, Page 24 Section 60485 What is Form 3520?6 Who Must File Form 3520?7 What is Reported on Form 35208 When is Form 3520 Due?9 Can You Apply for an Extension for Form 3520?10 What if You File […]
Contents1 International Tax Evasion2 Introduction to International Tax Evasion3 26 U.S.C. 72014 International Tax Evasion Example 5 Recent International Tax Evasion Cases6 Tax Evasion Penalties7 IRS Voluntary Disclosure Program (VDP)8 Current Year vs. Prior Year Non-Compliance 9 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)10 Need […]
Contents1 U.S. Taxation Rules for Residents or Citizens 2 All Income May be Taxable3 Living Overseas vs in the United States4 Foreign Sourced Income vs Domestic Source5 Foreign Tax Credits6 Foreign Earned Income Exclusion7 Treaty Elections and Limitations8 Reporting of Foreign Assets, Accounts, and Investments9 Avoiding […]
Contents1 Foreign Account and Tax Reporting2 FBAR (FinCEN Form 114)3 Form 8938 (FATCA)4 Form 5471 (Foreign Corporations)5 Form 3520 (Foreign Gifts and Trusts)6 Form 8621 (Passive Foreign Investment Companies)7 Procedures for Compliance8 VDP and OVDP 9 Streamlined Filing Compliance Procedures SDOP/SFOP 201410 Delinquency Procedures (DFSP and […]
Contents1 When does the IRS Consider Income to be Taxable?2 Foreign Income from Employment3 Foreign Capital Gains4 Foreign Dividend and Interest Income5 Foreign Pension Income6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful […]
Contents1 Tax Evasion and Fraud2 Offshore Earned Income3 Offshore Passive income4 Criminal Willfulness 5 Criminal FATCA6 Submitting False Documentation7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Need Help Finding an Experienced Offshore Tax Attorney?10 Golding & Golding: About […]
Contents1 Streamlined Domestic vs Streamlined Foreign2 Streamlined Domestic Offshore Procedures (SDOP)3 SDOP Requires Timely Filed Tax Returns4 5% Title 26 Miscellaneous Offshore Penalty5 Streamlined Foreign Offshore Procedures6 Original Tax Returns7 Two Tests to Qualify as a Foreign Resident 8 Common Issues for Both Streamlined Programs9 Taxpayers […]
Contents1 Is it Tax Planning, Avoidance, or Tax Fraud?2 Proper Tax Planning3 Gray Area Tax Planning4 Tax Fraud5 Golding & Golding: About Our International Tax Law Firm Is it Tax Planning, Avoidance, or Tax Fraud? When a US Taxpayer wants to reduce their tax liability, the […]
Contents1 Did IRS Reject Your Form 3520 CDP Claims?2 Did Your Tax Attorney Guarantee You Would Win?3 You Have 30-Days to Petition the Tax Court 4 Missed 30-day CDP Petition Deadline?5 Golding & Golding: About Our International Tax Law Firm Did IRS Reject Your Form 3520 CDP […]
Contents1 IRS Files Notice of Appeal in Farhy 2 The Outcome of Farhy Will Have a Big Impact3 Filing Late Form 5471 4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 Golding […]
Contents1 Wealthy Non-Filers are Being Aggressively Targeted2 What the IRS Says About Millionaire Non-Filers3 What Should Millionaire Non-Filers Do?4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 Golding & Golding: About […]
Contents1 Residents of Puerto Rico and IRS Tax Audits2 High-Dollar Scheme in Puerto Rico3 What Does This Means for U.S. Residents in Puerto Rico?4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 […]
Contents1 What is a John Doe Summons?2 IRC 76093 IRM 25.5.7.1.2 4 Who Has to Approve a John Doe Summons?5 What are the Procedures for Issuing a John Doe Summons6 John Doe Summons Must Have a Necessary Purpose7 No Notice Requirement for Enforcement8 Golding & Golding: About […]
Contents1 PFIC Tax Implications2 Acquiring a Foreign Mutual Fund 3 Making a PFIC Election 4 Timely Election vs Late Election5 Dividend Reinvestment vs Dividend Distribution6 Are Dividends Distributed from the Outset7 Selling/Redeeming the PFIC8 Switch-Outs and Mirror Funds9 Golding & Golding: About Our International Tax Law Firm […]
Contents1 Flat-Fee Streamlined Filing Lawyers2 Low Up-Front Hourly Fee Bait-and-Switch for Streamlined Cases3 Benefits of Flat-Fee Streamlined Filing Lawyers4 International Tax Lawyer Specialist Team: Golding & Golding Flat-Fee Streamlined Filing Lawyers Flat-Fee Streamlined Filing Lawyer Fees: With the IRS having both closed OVDP (2018) and ended […]
Contents1 Streamlined Filing Compliance Procedures2 Purpose of the Streamlined Filing Compliance Procedures3 What is Streamlined Filing Compliance “Non-Willfulness”4 Non-Willfulness is Required for Streamlined Filing Compliance Procedures5 Increased Enforcement of IRS Offshore Penalties6 Current Year vs Prior Year Non-Compliance 7 Avoid False Offshore Disclosure Submissions (Willful vs […]
Contents1 IRS Voluntary Disclosure Program Updated Practice2 IRS Voluntary Disclosure Program Basics3 New IRS Voluntary Disclosure Program Procedures4 How the Updated IRS Voluntary Disclosure Program Works5 IRS Voluntary Disclosure Program Steps6 What are the Fees for Hiring an Offshore Disclosure Attorney?7 Golding & Golding: About Our […]
Contents1 Are You Under Criminal Tax Investigation?2 Use an Attorney3 Be Careful What You Divulge to the Government4 Taxpayers May Already be Under Government Surveillance5 Sudden Change of Behavior May Infer Criminal Avoidance6 Watch Who You Trust7 Current Year vs Prior Year Non-Compliance 8 Avoid False […]
Contents1 A Resident Alien Guide to Income Taxation2 All Income May be Taxable3 Living Overseas vs in the United States4 Foreign Sourced Income vs Domestic Source5 Foreign Tax Credits6 Foreign Earned Income Exclusion7 Treaty Elections and Limitations8 Reporting of Foreign Assets, Accounts, and Investments9 Avoiding Taxes […]
Contents1 Streamlined Domestic Offshore Procedures2 Benefits of the Streamlined Procedures3 Purpose of IRS Streamlined Domestic Offshore Program4 Streamlined Domestic Offshore Eligibility Criteria5 Were You Non-Willful?6 Non-Willful vs. Lower Standards of Willfulness 7 Did You Previously File “Timely” Tax Returns?8 Are You Currently Under Audit or Examination9 Are […]
Contents1 Streamlined Foreign Offshore Procedures2 Purpose of the Streamlined Foreign Offshore Procedures3 Who is Eligible for the Program?4 Other Offshore Penalties you can Avoid5 IRS Form 14653 Streamlined Foreign Non-Willful Certification 6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Need Help Finding an Experienced Offshore […]
Contents1 Gifts from Foreign Persons 2 IRS Reporting of Gifts From Foreign Persons3 The IRS wants to Track the Money4 Who Reports Gifts from Foreign Persons to the IRS?5 Foreign Individual vs. Foreign Entity6 Form 3520 Examples7 Distributions from a Foreign Trust8 Late Filing Penalties May […]