Contents1 Streamlined Domestic Offshore Procedures for U.S. Residents2 Purpose of the IRS Streamlined Program3 Eligibility Criteria for U.S. Residents 4 Treatment & Scope of IRS Streamlined Procedures5 IRS Form 14654 Non-Willful Certification 6 First Try Streamlined, then go OVDP?7 Golding & Golding: About our International Tax Law Firm8 […]
  Contents1 FBAR Penalties & the IRS2 IRS Offshore Enforcement3 How do FBAR Penalties Work?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 IRS Voluntary Disclosure Program (Updated Practice)2 New IRS Voluntary Disclosure Program Procedures3 How the Updated Program Works4 IRS Voluntary Disclosure Program Steps5 Golding & Golding: About Our International Tax Law Firm IRS Voluntary Disclosure Program (Updated Practice) New IRS Voluntary Disclosure Program Procedure Update: The […]
Contents1 Depreciation of Foreign Rental Property2 What is Rental Property Depreciation?3 Example of How is Foreign Rental Property Depreciated?4 What is the Immediate Benefit of Depreciation?5 Non-Compliance with U.S. Tax Law6 Golding & Golding: About our International Tax Law Firm Depreciation of Foreign Rental Property Depreciation […]
Contents1 Wealth Squad: IRS Targets High Net-Worth Taxpayers2 IRM 4.52.1: Global High Wealth Program & the Wealth Squad3 What is the Purpose of the Wealth Squad Program?4 How does the Wealth Squad Program Work?5 Are You in U.S. Tax Compliance?6 Golding & Golding: About Our International […]
? Contents1 Covered Expatriates2 Expatriation Tax 3 Golding & Golding: About Our International Tax Law Firm Covered Expatriates Covered Expatriate:When a person is either a U.S Citizen or Long-Term Legal Permanent Resident, and they want to exit the U.S. permanently — they may have IRS tax consequences.  […]
Contents1 What is Expatriation?2 Expatriation is not Just for U.S. Citizens3 Are You a Covered Expatriate?4 Exit Tax: Mark-to-Market & Deemed Distribution5 Form I-407 vs. DS-4079-40836 Covered Expatriate Post Expatriation7 Golding & Golding: About Our International Tax Law Firm What is Expatriation? What is Expatriation: Expatriation […]
Contents1 FBAR Amnesty 2 Civil FBAR Penalties3 Criminal FBAR Penalties4 Golding & Golding: About Our International Tax Law Firm FBAR Amnesty  FBAR Amnesty: The IRS has developed multiple foreign bank account program amnesty options for FBAR and FATCA related non-compliance. These programs are available to Taxpayers worldwide. […]
Contents1 Streamlined Foreign Offshore Procedures2 Purpose of the Streamlined Foreign Offshore Procedures3 Who is Eligible for the Program?4 IRS Form 14653 Non-Willful Certification 5 First Try Streamlined, then go OVDP?6 Are the IRS Streamlined Foreign Procedures Ending in 2020?7 Golding & Golding: About our International Tax Law […]
  Contents1 IRS OVDP Lawyers Worldwide2 How to Interview IRS Offshore Counsel3 Golding & Golding: About Our International Tax Law Firm IRS OVDP Lawyers Worldwide OVDP Lawyers: Our OVDP lawyers specialize exclusively in Offshore Disclosure. The IRS international tax lawyers at Golding & Golding represent clients […]
Contents1 Offshore vs Streamlined Filing Compliance2 IRS Offshore Voluntary Disclosure Program (OVDP)3 IRS Streamlined Procedures4 Golding & Golding: About Our International Tax Law Firm Offshore vs Streamlined Filing Compliance OVDP vs Streamlined: Comparing OVDP vs Streamlined is complicated. U.S. Taxpayers who have not reported foreign accounts […]
Contents1 Tax Organizers2 5 Confidentiality Risks of Tax Organizers3 New Client vs. Current Client4 Attorney-Client Privilege Breach5 Misunderstanding the Tax Organizer Questions6 Offshore Accounts & Income7 Confidentiality of Information in the Tax Organizer8 Golding & Golding: About Our International Tax Law Firm Tax Organizers Tax Organizers: […]
  Contents1 FBAR Lawyers2 What is an FBAR?3 Interviewing FBAR Lawyers4 Beware of False Marketing Scams5 Golding & Golding: About Our International Tax Law Firm FBAR Lawyers FBAR Lawyers: When a U.S. person has unreported foreign accounts, they may need an FBAR Attorney to represent them. […]
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 Learning […]
  Contents1 Streamlined Filing Compliance Procedures2 Purpose of the Streamlined Filing Compliance Procedres3 What is Streamlined Willful or Non-Willful?4 Non-Willfulness is Required for Streamlined Filing Procedures5 Golding & Golding: About Our International Tax Law Firm Streamlined Filing Compliance Procedures Streamlined Filing Compliance Procedures (SFCP): The IRS […]
Contents1 IRS Letter 63112 What is IRC 965?3 Non-Compliance with IRC 9654 Did You Receive an IRS Letter 6311?5 Golding & Golding: About Our International Tax Law Firm IRS Letter 6311 IRS Letter 6311: IRS letter 6311 involves the Internal Revenue Code section 965 transition tax […]
Contents1 Nonresident Aliens & U.S. Rental Income2 Nonresident Alien Rental Income Compliance Group3 Unreported Income 4 30% Withholding 5 Lots of Undisclosed Income6 FIRPTA Concerns7 Golding & Golding: About Our International Tax Law Firm Nonresident Aliens & U.S. Rental Income Nonresident Aliens and U.S. Rental Income: With the […]
  Contents1 Form 54722 Purpose of Form 54723 Form 5472 Reporting Corporation4 Related Party Rules under Form 54725 Form 5472 Reportable Transaction6 Who is a Foreign Person?7 Exceptions From Filing Form 54728 Failure to File Form 54729 Form 5472 Penalties10 Reasonable Cause for 5472 Penalty Abatement11 […]
  Contents1 Assurance Vie U.S. Tax Compliance2 How does an Assurance Vie Work?3 Sidestep French Estate Laws4 U.S. Tax of Assurance Vie5 Assurance Vie and FBAR6 Assurance Vie and FATCA7 Assurance Vie and PFIC8 Golding & Golding: About our International Tax Law Firm Assurance Vie U.S. […]
Contents1 IRS Revenue Procedure 92-70 (5471 Dormant CFC Rules)2 IRS Revenue Procedure 92-703 5471 Dormant Foreign Corporation4 Background5 Scope for Dormant Corporations6 Recap of Dormant Corporation Requirements (92-70)7 General Procedure8 Relief9 Non-Compliance with U.S. Tax Law10 Golding & Golding: About Our International Tax Law Firm11 Interested […]
  Contents1 Legal Resident vs Tax Resident2 Legal Resident vs. Tax Resident3 What is the Substantial Presence Test?4 Worldwide Income Tax Due5 Illegal U.S. Residents & the IRS6 Foreign Account & Asset Reporting7 How to Avoid Offshore Fines and Penalties?8 Golding & Golding: About Our International […]
  Contents1 U.S. Taxation of Foreign Pension Plans2 Is Foreign Pension Plan Income Taxable?3 Common Issues involving U.S. Tax on Foreign Pension4 Is There A Bilateral Income Tax Treaty?5 Example of Foreign Pension & U.S. Tax Complexities6 Some Foreign Pension Plans May Be Excluded From U.S. […]
  Contents1 Assurance Vie & U.S. Tax2 How does an Assurance Vie Work?3 Sidestep French Estate Laws4 U.S. Tax of Assurance Vie5 Assurance Vie and FBAR6 Assurance Vie and FATCA7 Assurance Vie and PFIC8 Golding & Golding: About our International Tax Law Firm Assurance Vie & […]
Contents1 IRS Form 3520-A Reporting2 What is IRC 6048?3 Common Questions About Form 3520-A & Foreign Trusts4 What is Foreign Trust Reporting on Form 3520-A?5 Some Basics Terms and Definitions6 Golding & Golding: About our International Tax Law Firm IRS Form 3520-A Reporting Form 3520-A: The […]
Contents1 Form 35202 Who Files Form 3520?3 Reporting Foreign Gifts & Inheritance on 35204 Type of Foreign Gift5 How to Value a Gift from Foreign Person6 What is the Source of the Gift?7 Golding & Golding: About Our International Tax Law Firm8 Interested in Learning More […]
Contents1 International Tax Compliance & Offshore Reporting Guide2 Who is a U.S. Taxpayer?3 What does Tax on Worldwide Income (CBT) Mean?4 Foreign Income is Taxable5 What is Offshore Reporting?6 International Reporting Forms7 Filing an Extension (4868 vs 7004)8 Penalties for Offshore Noncompliance9 Disputing an International Tax […]
Contents1 Offshore Tax Evasion2 Is Tax Evasion a Crime?3 Offshore Tax Crimes4 Examples of Offshore Tax Evasion5 Examples of Non-Offshore Tax Evasion6 Offshore Amnesty: We All Have 20/20 Hindsight7 Golding & Golding: About Our International Tax Law Firm Offshore Tax Evasion Offshore Tax Evasion: For decades, […]
Contents1 Form 1040 Cryptocurrency Question2 Seven (7) Virtual Currency Tax Question & Answer FAQ3 What if I am out of Compliance for Cryptocurrency?4 Golding & Golding: About Our Tax Law Firm Form 1040 Cryptocurrency Question Form 1040 Cryptocurrency Question: The IRS has upped the ante when […]
Contents1 Foreign Passport, Leaving the US & Tax Consequences2 US Taxation on Worldwide Income3 Getting a Second Passport is not an Expatriating Act4 U.S. Citizens Must Formally Expatriate5 Green Card Holders/Permanent Residents6 Just Let my Green Card Lapse?7 Expatriating Act vs. New Passport or Citizenship8 Covered […]
    Contents1 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 Criminal FBAR Penalties6 Golding & Golding: About our International Tax Law Firm Delinquent FBAR Submission Procedures Delinquent FBAR Submission Procedures: […]
Contents1 Tax Fraud Statute of Limitations2 What is Tax Fraud?3 How Much Time for IRS to Pursue Tax Fraud?4 Civil Tax Fraud – How Long Can the IRS Go After You?5 Does the IRS Always Have Forever?6 Three Main IRS “Forever Statute” Situations To Be Aware […]
Contents1 Average Jail Time For Tax Evasion2 What is Tax Evasion?3 I.R.C. § 7201 – ATTEMPT TO EVADE OR DEFEAT TAX4 International Tax Evasion5 What Can You Do?6 Golding & Golding: About Our International Tax Law Firm Average Jail Time For Tax Evasion The average jail […]
Contents1 Offshore Tax Fraud vs Willful FBAR Standard of Proof2 Civil FBAR Willful Penalty3 FBAR Standard of Proof4 U.S. v. Garrity5 What Do the Courts Say?6 FBAR Civil Penalties are Just Money7 IRS Memoranda and the Higher Evidence Standard8 Criminal vs Civil Willfulness Distinguished9 Reckless Disregard & […]
  Contents1 Cryptocurrency Tax Lawyers2 What does a Cryptocurrency Lawyer do?3 Introduction to Cryptocurrency Tax & the IRS4 Short-Term vs. Long-Term Capital Gains example5 Income Tax & Cryptocurrency6 Tax Rules for Exchanging Cryptocurrency 7 You Received Cryptocurrency as a Gift8 You Received Cryptocurrency as an Inheritance (Step-up)9 […]
Contents1 Cryptocurrency Tax Audit2 Exchanging Crypto is Taxable Event3 Selling Crypto is Taxable4 Did You Receive Cryptocurrency as Employment Income?5 Are Cryptocurrency Hard Forks and Airdrops Taxable?6 Can you Claim 1031 Tax Deferred Treatment?7 Unreported Cryptocurrency?8 Golding & Golding: About Our Tax Law Firm Cryptocurrency Tax […]
Contents1 US Tax of Singapore CPF, Assets, & Income2 CPF (Central Provident Fund)3 CPF & U.S. Tax4 How is CPF Taxed in Singapore?5 Is CPF the Same as 401?6 Is CPF the Same as U.S. Social Security?7 Examples of U.S. Tax on Singaporean CPF8 CPF FBAR […]
  Contents1 Taxation of Australian Superannuation Funds in the US2 What is Superannuation?3 Is Superannuation Reported on a U.S. Tax Return?4 Are Employer Contributions Taxed?5 Reporting on a Tax Return to the IRS6 Golding & Golding: About Our International Tax Law Firm7 Less than 1% of […]
Contents1 Closer Connection Exception to the Substantial Presence Test2 What is the Substantial Presence Test?3 How the Closer Connecion Exception Works4 Foreign National Residing in the U.S.5 Example of Substantial Presence6 Closer Connection Test as provided by the IRS7 When You Cannot Claim Closer Connection to […]
  Contents1 Form 8938 2 Form 8938 Threshold & Requirements3 Form 8938 Threshold Filing Requirements4 Foreign Financial Asset Definition5 8938 Form Filing Deadline6 Late Filing Form 8938 Penalties7 Reasonable Cause Exception to Late Form 89388 Golding & Golding: About Our International Tax Law Firm Form 8938  Form […]
  Contents1 Cryptocurrency Tax Laws2 Increased IRS Cryptocurrency Tax Law Enforcement3 Cryptocurrency Tax FAQ4 Unreported Cryptocurrency?5 Golding & Golding: About Our Tax Law Firm Cryptocurrency Tax Laws Cryptocurrency Tax Laws: In the past five (5) years, cryptocurrency has taken center stage with the IRS. Even with […]
Contents1 IRS Letter 6173, 6174 & 6174-A2 IRS Letter 61733 IRS Letter 61744 Letter 6174-A5 Getting Into IRS Compliance6 Golding & Golding: About Our International Tax Law Firm IRS Letter 6173, 6174 & 6174-A IRS Letter 6173, 6174 & 6174-A: In recent years, the IRS has […]
Contents1 Unreported Foreign Accounts2 Penalties for Unreported Foreign Accounts3 Who Has to Report a Foreign Bank Account?4 How do I get into IRS Offshore Compliance?5 Golding & Golding: About Our International Tax Law Firm Unreported Foreign Accounts Unreported Foreign Accounts: U.S. persons with unreported foreign accounts […]
?   Contents1 Quiet Disclosure & the IRS2 10 Quiet or Silent Disclosure Risks3 IRS Enforcement of Offshore Penalties4 Statute of Limitations5 Golding & Golding: About Our International Tax Law Firm Quiet Disclosure & the IRS Quiet Disclosure IRS: When a U.S. person has unreported offshore […]
Contents1 Unreported Foreign Income2 Disclosing Unreported Foreign Income3 Common Questions about Overseas Income 4 Your Goal is Avoid Offshore Penalties5 Golding & Golding: About Our International Tax Law Firm Unreported Foreign Income Unreported Foreign Income: A Taxpayer who is a U.S. Person has very specific tax and […]
  Contents1 FBAR 2020 2 10 Common FBAR Questions & Answers (FAQ)3 Golding & Golding: About Our International Tax Law Firm4 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists FBAR 2020  FBAR 2020: The FBAR is the Foreign Bank and Financial Account Reporting Form (aka […]
?   Contents1 Accidental American, what is it?2 Foreign Account Tax Compliance for Overseas Residents3 FATCA & Accidental Americans (Common Questions)4 Foreign “Americans” Get A Raw Deal5 Golding & Golding: About Our International Tax Law Firm Accidental American, what is it? Accidental Americans & U.S. Tax: […]