202001.17
1

What is a PFIC (IRS Summary 2020)

Contents1 PFIC (Passive Foreign Investment Company)2 Taxation and Reporting the PFIC3 How to Report a PFIC4 Tax Rules5 What if I Never Reported the PFIC or Paid Tax?6 Golding & Golding (Board-Certified Tax Law Specialist) PFIC: Revisiting Passive Foreign Investments: PFIC is an IRS acronym that refers to Passive Foreign Investment Companies.  The acronym can…

202001.17
5

FATCA Reporting (IRS Summary 2020)

Contents1 FATCA Reporting 2 The Purpose of FATCA3 10 Important Facts about FATCA4 Golding & Golding (Board-Certified Tax Law Specialist) FATCA Reporting: FATCA Reporting is a key enforcement priority, and penalties for not disclosing foreign financial assets is on the rise. In 2020, the IRS will continue aggressive enforcement of FATCA reporting. FATCA (Foreign Account Tax Compliance…

202001.15
0

Eggshell Audit (IRS Summary 2020)

Contents1 Eggshell Audit2 Protection Against Self-Incrimination3 Reverse Eggshell Audits4 IRS Criminal Tax Investigations5 Pleading the 5th6 Intentional Misrepresentation vs. Truth7 Golding & Golding (Board-Certified Tax Law Specialist) Eggshell Audit: IRS High Risk Examination & Criminal Exposure: With an eggshell audit, the taxpayer is at a high risk for a potential IRS willful violation, tax fraud, and…

202001.15
9

Foreign Life Insurance Taxation (IRS Summary 2020)

Contents1 Foreign Life Insurance Taxation 2 What is a Foreign Life Insurance Policy?3 How to Report Foreign Policy Values4 Golding & Golding (Board-Certified Tax Law Specialist) Foreign Life Insurance Taxation: The foreign life insurance taxation rules are complicated. In general, a foreign life insurance policy is an important component of an investment portfolio. When a U.S….

202001.14
24

Australian Superannuation Tax Rules in the U.S. (Summary 2020)

Contents1 U.S. Tax on Australian Superannuation Funds2 Australian Superannuation Tax Treatment Rules Q &A3 Golding & Golding, Board-Certified Tax Law Specialist U.S. Tax on Australian Superannuation Funds: The U.S tax on Australian Superannuation Funds analysis is complicated and (unnecessarily) complex. U.S. persons who own an Australian Super may have a U.S. tax & reporting requirement…

202001.11
0

Can Green Holders Qualify for OVDP or Streamlined Procedures?

Do Green Holders Qualify for OVDP or Streamlined Procedures? Yes. Green Card Holders do qualify for the IRS (New) OVDP and the Streamlined Filing Compliance Procedures. The streamlined program is an IRS program designed to help non-willful taxpayers safely report offshore accounts, assets, investments and income. In light of the recent increased enforcement of foreign…

202001.05
2

Offshore Cryptocurrency Reporting (IRS Summary 2019-2020)

Contents1 Offshore Cryptocurrency Reporting2 FBAR Cryptocurrency 3 FATCA Form 8938 Cryptocurrency Reporting4 IRS Enforcement Initiatives5 Golding & Golding (Board-Certified Tax Law Specialist) Offshore Cryptocurrency & IRS: How to Report (2019-2020): The IRS rules for offshore reporting, and specifically foreign cryptocurrency reporting on FBAR & FATCA Form 8938 are still in flux. With the 2019 tax returns…

202001.01
3

IRS Offshore Penalties (2019-2020 Summary Update)

Contents1 IRS Offshore Penalties2  Golding & Golding (Board-Certified Tax Law Specialist) IRS Offshore Penalties: In recent years, the IRS Offshore Penalties have become progressively worse. How the IRS dings overseas assets & accounts, and issues offshore penalties can be complicated. The Internal Revenue Service has taken an aggressive approach towards foreign accounts compliance. The failure…

201912.30
1

Offshore Accounts and IRS Reporting Requirements (Summary 2020)

Contents1 Offshore Accounts & IRS (Reporting Rules & Requirements)2 Definitions3 What if I Never Reported to the IRS 4 Be Proactive, Get Into Compliance with Offshore Disclosure5 Golding & Golding, Board-Certified Tax Law Specialist Offshore Accounts: IRS Reporting Rules & Requirements: The reporting of Offshore Accounts is an enforcement priority for the IRS. The Internal Revenue…

201912.29
6

IRS Quiet Disclosure (Summary 2019-2020)

Contents1 IRS Quiet Disclosure2 10 Reasons to Avoid Quiet Disclosure3 IRS Enforcement of Offshore Penalties4 Statute of Limitations5 Why Hire Us?6 Offshore Disclosure Tax Amnesty: Golding & Golding (Board-Certified) IRS Quiet Disclosure: A Quiet Disclosure IRS involves the filing of late tax returns and international informational returns with the Internal Revenue Service. Quiet disclosure evolved…

201912.28
0

Offshore Voluntary Disclosure Program (IRS Summary 2020)

Contents1 Offshore Voluntary Disclosure Program2  Golding & Golding  Offshore Voluntary Disclosure Program: The Offshore Voluntary Disclosure Program  was launched back in 2009 by the IRS. Back in 2009, it was referred to as  the Offshore Voluntary Disclosure Initiative), but was later changed to Offshore Voluntary Disclosure Program . The idea behind the program, was that…

201912.28
5

Non-Willful FBAR Penalties (2019-2020 Update)

Contents1 Non-Willful FBAR Penalty2 Civil Penalties Non-Willful (and Willful) 3 Criminal Penalties4 Golding & Golding: Board Certified Tax Law Specialist5 How to Hire Experienced FBAR Penalty Mitigation Counsel Non-Willful FBAR Penalty: Understanding how the IRS issues a non-willful FBAR penalty(s) can be complex. In recent years, the IRS has taken an aggressive position towards foreign accounts…

201912.28
6

FBAR Penalties (IRS Summary 2020)

Contents1 FBAR Penalties2 Civil FinCEN FBAR Penalty (31 U.S.C. § 5321 et seq.)3 Criminal FBAR Penalty (31 C.F.R. §103.59)4 Recent Updates to FBAR 5 Common Client FBAR Penalty Questions 6 FBAR Penalty Lawyers – Golding & Golding, A PLC FBAR Penalties: The FBAR penalties are on the rise. The IRS has significantly increased enforcement of offshore bank account…