201801.21
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IRS Says FATCA Minimizes The Need for Offshore Voluntary Disclosure

IRS Says FATCA Minimizes The Need for Offshore Voluntary Disclosure For many individuals, businesses, and estates that are still debating whether they should enter the IRS Offshore Voluntary Disclosure Program or not — they should take caution. Is it Over for IRS Offshore Voluntary Disclosure? In a recent presentation, key representatives for the IRS have…

201801.21
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IRS Penalty Abatement (2018) – Foreign Accounts | Offshore Assets

IRS Penalty Abatement (2018) – Foreign Accounts | Offshore Assets In recent years, and due to the increased enforcement of FATCA (Foreign Account Tax Compliance Act) along with renewed interest in FBAR (Report of Foreign Bank and Financial Accounts) reporting, the IRS has been issuing significantly higher fines and penalties against individuals with unreported, undisclosed,…

201801.18
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Constructive Ownership of Foreign Stock – Attribution Reporting Rules

Constructive Ownership of Foreign Stock – Attribution Reporting Rules IRS form 5471 is difficult – even for the most experienced international tax professionals. It encompasses both international tax law and international business – along with bookkeeping and accounting. What is Form 5471? The goal of form 5471 is to provide the IRS sufficient information regarding…

201801.16
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Panama Foundation – U.S. Tax | IRS Offshore Disclosure Procedures

Panama Foundation – U.S. Tax | IRS Offshore Disclosure Procedures Forgetting all the recent press regarding the Panama papers, a Panama Foundation is a very common investment tool – or at least it was many years ago. A Panama Foundation takes on many similarities of a hybrid between a trust and a corporation. A Panama…

201801.12
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International Informational Returns – Tax Penalties | IRS Amnesty Options

International Informational Returns – Tax Penalties | IRS Amnesty Options Each year, the National Taxpayer Advocate issues a report to Congress summarizing the biggest issues with the tax code, the IRS enforcement of the tax code and what needs to be done to fix it. IRS Increases Penalty Enforcement One of the most disturbing trends…

201801.11
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U.S. Person For Tax Purposes (2018) – Foreign Income & Accounts

U.S. Person For Tax Purposes (2018) – Foreign Income & Accounts There is a common misconception involving when a foreign person is considered a U.S. Person for U.S. tax purposes. Specifically, how a non-US citizen is required to pay and report taxes and foreign accounts just as if they were US citizen. Here’s how the…

201801.10
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Foreign Income – IRS Rules (2018) | Investments, Accounts, & Assets

Foreign Income – IRS Rules (2018) | Investments, Accounts, & Assets Foreign Income is usually broken down into one of the following categories: Investment Income Dividend Income Interest Income Capital Gain  Foreign Account Income Foreign Asset Income Foreign Income  Foreign Income Reporting has become an IRS enforcement mainstay. Depending on the facts and circumstances of your…

201801.10
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FATCA, CRS & AEOI – Dangerous Maze of Foreign Account Reporting

FATCA, CRS & AEOI – Dangerous Maze of Foreign Account Reporting In the early stages of FATCA (Foreign Account Tax Compliance Act) enforcement, if a US person had unreported foreign accounts, and their bank or Foreign Financial Institution wanted to become compliant they would send the client a FATCA Letter. Now, with the implementation of…

201801.08
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Undeclared Income from FBAR or FATCA Assets – IRS 6 Year SOL

Undeclared Income from FBAR or FATCA Assets – IRS 6 Year SOL One of the biggest misconceptions involving the IRS, International Tax Law and the Statue of Limitations, is how much time the IRS has to go after a person who has international tax related issues. International or Foreign Income Audit Unfortunately, unlike domestic related…

201801.05
1

FBAR Litigation – Tax Court, District Court, Court-of-Claims & Appeals

FBAR Litigation – Tax Court, District Court, Court-of-Claims & Appeals FBAR Litigation is on the rise. As the IRS issues increasingly high penalties against individuals (Usually penalties which far outweigh any “Crime,”) the number of people trying to fight these FBAR penalties in court will continue to rise. FBAR Litigation There are various methods for…

201801.04
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PFIC Rules – Foreign Investment Tax Trap | International Tax Planning

PFIC Rules – Foreign Investment Tax Trap | International Tax Planning Over the years, we have spoken with thousands of clients involving a broad range of complex international tax issues. Many of these complex issues involve matters regarding PFIC Reporting and Taxes. PFIC Rules Why are PFICs so hard? That is because the definition of a…