Contents1 A Surprising FBAR Victory May Be Cut Short2 Is the FBAR an IRS Form?3 Non-Resident vs Resident for FBAR4 Non-Resident FBAR Filing Requirements5 Resident FBAR Filing Requirements6 What is at Stake in Aroeste?7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs Prior […]
Contents1 Fraudulent Tax Deduction Promoters Get Hefty Prison Sentences2 Sold Over $1.3 Billion in Fraudulent Tax Deductions3 Late Filing Penalties May be Reduced or Avoided4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore […]
Contents1 Moore vs. United States (Sup Ct.)2 U.S. Constitution, Sixteenth Amendment3 IRC 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 the Supreme Court […]
Contents1 Taxpayer Prevails in Federal Court with FBAR Treaty Argument2 What the IRS says (Pub 5569)3 The Court Rules in Favor of Taxpayer on FBAR4 Late Filing Penalties May be Reduced or Avoided5 Current Year vs Prior Year Non-Compliance 6 Avoid False Offshore Disclosure Submissions (Willful […]
Contents1 Reasonable Cause International Penalty Relief2 Reasonable Cause Exception to Penalty Relief3 What is Reasonable Cause?4 Information Return Penalty Relief5 Other Factors to Consider for Reasonable Cause6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure […]
  Contents1 The Penalty Relief Programs for Late International Return Filing 2 Voluntary Disclosure (VDP/OVDP)3 Streamlined Procedures (SFCP/SDOP/SFOP)4 IRS Delinquency Procedures5 Delinquent FBAR Submission Procedures (DFSP)6 Delinquent International Information Return Submission Procedures (DIIRSP)7 Reasonable Cause8 Late Filing Penalties May be Reduced or Avoided9 Current Year vs […]
  Contents1 A New Expat Tax Planning Guide for U.S. Taxes2 What is the Expats U.S. Person Tax Status?3 Form 1040 vs Form 1040NR4 Does the Expat Qualify for a Treaty Election?5 Does the Expat Qualify for a Substantial Presence Exception?6 Foreign Earned Income and Housing7 […]
Contents1 A (New) Tax Fraud Update2 First, What is Tax Fraud?3 Civil vs Criminal Tax Fraud4 Important 26 and 31 U.S.C Statutes5 Malta Retirement Schemes6 High Net Worth with Unfiled U.S. Returns 7 Puerto Rico Act 608 Fraudulent Transfer of Foreign Assets9 Inaccurate Expatriation Net Worth10 […]
  Contents1 FBAR Update 2 2023 FBAR Supreme Court Case3 FBAR Filing Requirements and Due Date4 Penalties for FBAR5 IRM (Internal Revenue Manual)6 Willfulness FBAR Cases7 Burden of Proof in FBAR Cases8 Defenses to FBAR9 Late Filing Penalties May be Reduced or Avoided10 Current Year vs Prior […]
Contents1 Defending Against FBAR Penalties2 Non-Willfulness3 Reasonable Cause Defense to Non-Willfulness4 Reduced Non-Willful Penalties (See IRM)5 A Warning Letter In lieu of Penalties6 Willfulness7 Is the Taxpayer Non-Willful?8 Mitigating Willful Penalties9 Pre-Penalty Avoidance with FBAR Amnesty10 Late Filing Penalties May be Reduced or Avoided11 Current Year […]
Contents1 I Reside Overseas and Owe U.S. Taxes 2 Example of When an Expat Owes Taxes3 Taxpayer Has Not Had His Passport Revoked4 What Can a Non-Willful Taxpayer Do to Get Compliant?5 Willful Tax Compliance6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior […]
Contents1 Taxpayer with FBAR Penalties Forced to Repatriate Money2 Late Filing Penalties May be Reduced or Avoided3 Current Year vs Prior Year Non-Compliance 4 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)5 Need Help Finding an Experienced Offshore Tax Attorney?6 Golding & Golding: About Our International […]
Contents1 Are You at Risk of Committing Tax Fraud2 Is Tax Fraud a Crime?3 Will I go To Jail for Tax Fraud?4 Examples of Tax Fraud or Evasion5 How are Tax Fraud and Tax Evasion Investigated?6 Sentencing Guidelines7 Late Filing Penalties May be Reduced or Avoided8 […]
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 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 A Criminal FBAR Sentence for Tax Amnesty Fraud Explained2 The Taxpayer was an Accountant3 Govt. Alleges False Non-Willful Streamlined Application 4 The U.S. Dislikes Swiss Bank Accounts5 Failure to File FBAR6 Misrepresentations to the IRS7 Sentencing Guidelines8 Current Year vs. Prior Year Non-Compliance 9 Avoid […]
Contents1 International Information Returns2 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 Reduced or Avoided10 […]
Contents1 IRS Compliance Targets High-Income Taxpayers and FBAR2 IRS 2023/2024 Enforcement Takes Shape3 Prioritization of high-income cases4 Expansion of pilot focused on largest partnerships leveraging Artificial Intelligence (AI). 5 Greater focus on partnership issues through compliance letters. 6 Priority areas for targeted compliance work in FY 20247 […]
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 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 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 What Happens If You Do Not File FBAR (FinCEN 114)?2 Reasonable Cause to Avoid FBAR Penalties3 Delinquent FBAR4 Non-Willful FBAR Penalties5 Willful FBAR Penalties6 Criminal Penalties7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs Prior Year Non-Compliance 9 Avoid False Offshore […]
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 What are the Benefits to the Taxpayer?3 IRS Voluntary Disclosure Program Basics4 New IRS Voluntary Disclosure Program Procedures5 Offshore Accounts, Assets & Income6 U.S. Income Reporting7 Why Must the Money Be from Legal Sources?8 When is Criminal Prosecution Recommended?9 How […]
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 […]