Contents1 Reasonable Cause to Abate IRS Penalties2 Maggie Did Not Report a Foreign Gift or Business3 The Protest Letter to Prove Reasonable Cause4 What Goes into a Reasonable Cause Letter?5 Beware of Hidden Reasonable Cause Tripwires and Landmines6 Appeal or CDP Hearing7 Late-Filing Disclosure Options8 Quiet […]
? Contents1 A Foreign Information Return Penalties Overview2 International Reporting Requirements3 First, Unfiled International Reporting Forms Lead to Indefinite Enforcement4 Large Foreign Information Return Penalties and Several Methods of Enforcement5 FBAR6 Form 3520 Trust7 Form 3520- Gifts8 Form 3520-A9 Form 5471 Penalties10 Form 5472 Penalties11 […]
Contents1 How the IRS Scrutinizes Form 3520 Part IV (Gifts and Inheritance)2 Part IV Form 3520 (What is Required)3 Timeliness is Key4 Meeting the Form 3520 Threshold5 Late Filing Penalties May Be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 Avoid False Offshore Disclosure […]
Contents1 Disclosure of Foreign Assets by U.S. Taxpayers2 Foreign Bank Accounts3 Foreign Stock Accounts and Individually Held Stock4 Foreign Mutual Funds and ETFs5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore […]
Contents1 Navigating Form 8938 to Avoid Triggering IRS Violations2 First, What is FATCA?3 Form 8938 is Not the Same as FBAR4 Timely Filing: Form 8938 is Not on Automatic Extension5 Form 8938 Requires Assets and Accounts6 Do Not Intentionally Omit Accounts on Form 89387 Form 8938 […]
Contents1 Navigating Form 3520 to Avoid Triggering IRS Violations2 File Form 3520 Timely3 Use Accurate Form 3520 Values4 Submit Form 3520 to the Correct IRS Office5 Late-Filing Disclosure Options6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False […]
Contents1 Protecting Yourself and Clients in IRS Criminal Investigations2 Taxpayers3 Is the Taxpayer Already Under Investigation?4 Taxpayer Must Be Careful in a Civil Audit5 Did The IRS Special Agents Contact You?6 Did the Taxpayer Receive a Summons or Subpoena?7 Tax Professionals8 Tax Professionals Should Probably […]
Contents1 Misleading IRS Voluntary Disclosure Submission Leads to Indictment2 Defendant allegedly hid millions in unreported Assets in Series of Swiss Bank Accounts3 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 […]
Contents1 Second-Guessing Your Tax Attorney, Can You Cancel?2 The Attorney Was Fear-Mongering You3 Attorney Falsely Claims to Be Board-Certified4 Hourly-Fees Gone Awry5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)8 Need […]
Contents1 How Expat Plan B Companies Swindle Americans2 Case Study: Devin the American Who Wants to Reduce His Taxes3 They Do Not Explain About Expatriation Until After they have his Money4 Practice Tip: Giving Up Citizenship is a Big Decision for Americans5 Additional Forms, Costs, […]
Contents1 Common Offshore Tax Fraud and Evasion Risks (Examples)2 First, Willful or Non-Willful?3 Avoid Fear-Mongering, Free Consultations & False Claims of Being ‘Board-Certified’4 Foreign Accounts, Assets, and Income5 John Doe Summons6 Expatriation Tax Crime7 Late Filing Penalties May be Reduced or Avoided8 Late-Filing Disclosure Options9 Streamlined […]
Contents1 Expat Tax Advice Tips for International Citizens 2 Expats are Required to File Taxes, FBAR, and FATCA 3 Which Foreign Accounts Are Reportable?4 Different Tax Forms, Different IRS Due Dates5 Treaty Election Still Requires International Reporting6 A Treaty Election May Exempt FBAR7 Report Gross Income and […]
Contents1 Streamlined Foreign Offshore Procedures with Examples2 Non-Willfulness Requirement3 Taxpayer is Not Under Audit or Already Penalized4 Foreign Resident 330-Day Rule or Substantial Presence Test5 No Title 26 Offshore Penalty under SFOP6 SFOP Allows for Original Tax Return Filing7 Late Filing Penalties May be Reduced […]
Contents1 Streamlined Domestic Offshore Procedures (Examples)2 Non-Willfulness Requirement3 Taxpayer is Not Under Audit or Already Penalized4 Previously Timely Filed U.S Tax Returns 5 5% (Title 26) Offshore Penalty Instead of Multiple FBAR/Form 8938 Penalties6 Exceptions to the 5% Penalty7 Late Filing Penalties May be Reduced or […]
Contents1 Streamlined Filing Compliance Procedures2 Non-Willfulness Requirement3 Taxpayer is Not Under Audit or Already Penalized4 Domestic Streamlined Filing Requirements5 Previously Timely Filed U.S Tax Returns 6 5% (Title 26) Offshore Penalty Instead of Multiple FBAR/Form 8938 Penalties7 Exceptions to the 5% Penalty8 Foreign Streamlined Filing Requirements9 Foreign […]
Contents1 Taxpayers Have a Difficult Choice in Filing a Missed Form 35202 First, Will the New IRS Commissioner Accept the Proposed Changes?3 Delinquency Procedures/Reasonable Cause4 Streamlined Procedures5 About Form 3520 Filing (with Common Examples)6 Form 3520 Foreign Gift7 Form 3520 Foreign Inheritance8 Form 3520 Trust Distribution9 […]
Contents1 Examples of Offshore Investment Strategies to Avoid2 Forming a Hollow Foreign Entity3 Opening Accounts Under Third Parties4 Numbered or Anonymous Accounts5 How the IRS Finds You6 Taxpayers Should Avoid IRS/FBAR Quiet Disclosures7 Late-Filing Disclosure Options8 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)9 Streamlined Domestic Offshore Procedures […]
Contents1 Offshore Criminal Tax Help Guide for CPA, Lawyers & Clients2 First, Taxpayers and Tax Professionals Can Both Get into Trouble 3 IRS and FBAR Quiet Disclosure4 False Streamlined Offshore Statement5 Offshore Tax Fraud and Evasion6 Late-Filing Disclosure Options7 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)8 Streamlined Domestic […]
Contents1 Opening Foreign Bank Account Tax Implications 2 First, Reporting vs Income3 No Tax Implication from the Foreign Account4 Tax Implication of Using a Foreign Account5 Reporting Requirements 6 FBAR (FinCEN Form 114)7 Form 8938 (FATCA)8 Form 86219 Form 352010 Form 3520-A11 Late-Filing Disclosure Options12 Streamlined Filing Compliance […]
Contents1 How to Handle Multi-Year Late or Amended Tax Filings 2 First, Beware of Fear-Mongering, Free Consultations & False Claims of Being ‘Board-Certified’3 Failing to Report Foreign Earned Income4 Failing to Report Foreign Passive Income5 Unreported Foreign Accounts6 Foreign Mutual Funds and ETFs7 Unreported Foreign Gifts […]
Contents1 CPA Offshore Reporting Negligence Examples 2 Visa Holder and Unfiled Returns/Assets3 Foreign Income Not Included4 Pension Account Not Reported5 Form 8621 and PFIC6 Late-Filing Disclosure Options7 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)8 Streamlined Domestic Offshore Procedures (SDOP, Non-Willful)9 Streamlined Foreign Offshore Procedures (SFOP, Non-Willful)10 Delinquent FBAR […]
Contents1 Retirement Plan Treatment for U.S. Exit Tax 2 Retirement Plans in General3 U.S. Retirement Plans (401K and Equivalent)4 U.S. Retirement Supplement (IRA)5 Foreign Retirement Plans and Step-up Basis6 Restricted Stock (Non-Vested)7 Should You Withdraw U.S. Pension or Not?8 Late-Filing Disclosure Options9 Streamlined Filing Compliance Procedures (SFCP, […]
Contents1 IRS Passport Restrictions2 Example Language From CP508C3 Failure to File Returns (Unaware)4 Taxpayers Must Claim the Foreign Earned Income Exclusion5 Foreign Tax Credits Must Also be Claimed on the Tax Return6 What About FBAR Non-Compliance?7 Late Filing Penalties May be Reduced or Avoided8 Current Year […]
Contents1 What is IRS Form 8621?2 What is a PFIC?3 PFIC/CFC Crossovers, GILTI, Subpart F and Excess Distributions4 Which Forms to File to Report PFIC?5 PFIC Taxation6 Making PFIC Elections7 No PFIC Election – Excess Distributions8 Late Election/Purging PFIC Election9 Exceptions to Filing the Form 862110 […]
Contents1 Offshore Voluntary Disclosure vs. Streamlined Procedures2 First, What is OVDP/VDP?3 Willfulness and OVDP/VDP4 Streamlined Procedure Non-Willfulness Requirement5 Taxpayer is Not Under Audit or Already Penalized6 Domestic Streamlined Filing Requirements7 Previously Timely Filed U.S Tax Returns 8 5% (Title 26) Offshore Penalty Instead of Multiple FBAR/Form 8938 […]
Contents1 8 Exit Tax Traps When Expatriating from the United States2 First, Being Pressured by an Attorney to ‘Act Fast’3 Attorneys Who Lie About Being “Certified”4 5 Years Tax Compliance (Timing)5 Making an NRA Election in Year 86 Foreign Pension Plans and Exit Taxes7 Traditional IRA […]
Contents1 IRS Form 3520 2 The Purpose of Form 35203 Form 3520 Foreign Gift4 Form 3520 Foreign Inheritance5 Form 3520 Trust Distribution6 Form 3520/3520-A Ownership of Foreign Trust7 Related Persons8 Trust Reporting Exceptions (2020-17 and Proposed Regulations)9 The Tip of the Iceberg10 Late Filing Penalties May […]
Contents1 IRS Form 8621 with Examples: Foreign Mutual Funds and ETFs2 Foreign Mutual Fund and ETF Reporting3 Foreign Mutual Fund and ETF Tax4 Foreign Pension/Treaty Exception5 Foreign Corporations Used to Hold Passive Investments6 PFIC Elections7 *Crossover with Subpart F Income8 The Tip of the Iceberg9 Late […]
Contents1 IRS Form 8938 with Examples: Specified Foreign Assets2 Who Has to File Form 8938?3 What are the Form 8938 Threshold Requirements?4 What is the Form 8938 Due Date?5 What Types of Foreign Assets are Reportable?6 What if Form 8938 is Filed Late (Penalties)7 The Tip […]
Contents1 Form 8854 and Expatriation2 First, Net Worth vs Exit Tax3 Mark-to-Market Gains4 Eligible Deferred Compensation5 Ineligible Deferred Compensation6 Specified Tax Deferred Accounts7 The Tip of the Iceberg8 Late Filing Penalties May be Reduced or Avoided9 Current Year vs. Prior Year Non-Compliance 10 Avoid False […]
Contents1 IRS Form 8865 with Examples 2 What is a Foreign Partnership?3 Who Has to File Form 8865?4 What is Constructive Ownership for Form 8865?5 Constructive Ownership Exception6 When is Form 8865 Due?7 Civil and Criminal Penalties for Failing to File Form 88658 Late Filing Penalties May […]
Contents1 How to Navigate IRS Foreign Reporting Noncompliance Penalties2 Pre-IRS Foreign Penalty Assessment3 FBAR Penalty Assessment4 IRS International Reasonable Cause Penalty Abatement5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore Disclosure […]
Contents1 Overview of New Immigrant U.S. Tax Rules 2 Worldwide Income Taxation3 Foreign Bank Account Reporting (FBAR)4 Form 8938 (FATCA)5 Form 3520 Gift6 The Tip of the Iceberg7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs. Prior Year Non-Compliance 9 Avoid False Offshore […]
Contents1 A Beginner’s Guide to Resident Alien Taxation by Visa Type2 First, What is the Substantial Presence Test?3 H-1B Work Visa4 L-1 Transfer Visa5 B1/B2 Tourist Visa6 EB-5 Investment Visa7 F-1 Student Visa8 Closer Connection Exception9 Treaty Elections10 Late Filing Penalties May be Reduced or Avoided11 […]
Contents1 Do I Owe an Exit Tax when I Leave the U.S.2 First, Net Worth vs Exit Tax3 Mark-to-Market Gains4 Eligible Deferred Compensation5 Ineligible Deferred Compensation6 Specified Tax Deferred Accounts7 The Tip of the Iceberg8 Late Filing Penalties May be Reduced or Avoided9 Current Year vs. […]
Contents1 Is Unreported Foreign Income or Assets Criminal?2 Unreported Foreign Income3 Unreported Foreign Accounts and Assets4 Tax Fraud and Tax Evasion5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions […]
Contents1 Ending Your U.S. Status Has Tax Complications2 You Must Be Compliant Before You Terminate Status3 Five-Year Tax Compliance Rule4 What is Considered the Date of Expatriation?5 Relief Procedures Have Very Specific Eligibility Requirements6 Accidental American Status is Often the Catalyst7 401K for Net Worth vs […]
Contents1 Navigating the Challenges of Foreign Asset Offshore Disclosures2 Willful vs Non-Willful3 Which Offshore Disclosure Program is Right for You?4 Timing the Foreign Account Disclosure5 Understanding the Complexity of Offshore Reporting6 Joint Accounts with Non-Disclosing Taxpayers7 Late Filing Penalties May Be Reduced or Avoided8 Current Year […]
Contents1 Don’t Settle for an Inexperienced Local Foreign Account Lawyer2 Offshore Disclosure Lawyers Can be Licensed in Any State3 You Only Get One Shot at it4 Foreign Asset Reporting Does Not Require In-Person Meetings5 Only a Few Offshore Disclosure Specialists have 25 Years of Experience, are […]
Contents1 Can I Talk to a CPA About My Undisclosed Offshore Assets?2 Late FBAR Attorney-Client Privilege3 What is the Accountant-Client Privilege for Delinquent FBAR?4 Privilege Agreements Between Accountants and Attorneys are Limited5 Late Filing Penalties May Be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance […]
Contents1 IRS Targets Foreign Accounts, Assets, Trusts, and Gifts2 Are the Streamlined Procedures Right for You?3 Automatically Assessed Penalties for International Violations are Common4 The Reality of IRS International Penalties5 Tax Court or District Court/Court of Claims6 Financial Limitations to Filing in Federal Court7 Late Filing […]
Contents1 Film Producer Indicted for Offshore Tax Violations2 Defendant Allegedly Concealed More than $25M Abroad, Causing More than $5M in Loss to IRS3 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 […]
Contents1 Form 3520 and Penalties2 Why Did Taxpayer Receive a Form 3520 Penalty?3 30-Days to Show Reasonable Cause4 Did The Taxpayer Already Submit a Reasonable Cause Statement with Form 3520?5 Was Taxpayer’s Reasonable Cause Statement Even Considered?6 Should Taxpayers Appeal the CP15 Form 3520 Penalty?7 What […]
Contents1 The Pitfalls of Undeclared Foreign Financial Accounts2 First, Which Tax Forms are Required for Foreign Accounts?3 FATCA Bank Letter Leads to IRS Undisclosed Foreign Account Audits4 FBAR Audit or Examination5 Willful or Non-Willful6 Fines and Penalties7 Criminal Investigation8 Late Filing Penalties May Be Reduced or […]
> Contents1 A Primer on Tax Fraud Violations2 The Office of Fraud Enforcement Advisor Program3 What is Clear and Convincing Evidence?4 Fraud Penalties (26 U.S.C. 6663)5 Examples of Potential Tax Fraud6 Falsifying Information to a Foreign Financial Institution7 Intentionally Failing to Include Foreign Income on a […]
Contents1 What is an Offshore Tax Law Specialist?2 First, Becoming a (Board-Certified) Tax Lawyer Specialist3 Is a CPA ‘Board’ the Same as a Board-Certified Tax Lawyer Specialist?4 American Bar Association Article About Attorney Experts5 How Long Has the Attorney Been Licensed?6 Are They a Board-Certified Tax […]
Contents1 How False Statements Increase Criminal Tax Audit Risks2 Not Disclosing Foreign Accounts and Assets3 Not Disclosing Foreign Income4 Misrepresentations to the Foreign Bank About U.S. Status5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs Prior Year Non-Compliance 7 Avoid False Offshore Disclosure […]
Contents1 What are IRS Foreign High-Risk Tax Audits2 Intentionally Unreported Foreign Income3 Willfully Unreported Foreign Accounts Assets4 Incomplete FBAR/FATCA5 Misrepresenting U.S. Person Status to Foreign Bank6 3rd Party Fraudulent Conveyance7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs Prior Year Non-Compliance 9 Avoid […]
Contents1 What Does Being Board-Certified in Tax Law Mean?2 First, How to Protect Yourself3 Licensed as a CPA4 An Attorney ‘Board-Certified’ By the State Bar5 What if the Attorney Is Not a ‘Board-Certified Specialist’ But Claims to Be?6 Golding & Golding: About Our International Tax Law […]
Contents1 Supreme Court Rules in Favor of the Transition Tax2 What is Section 965?3 Key Parts of the Supreme Court’s Ruling4 What Does This Mean for Taxpayers?5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs Prior Year Non-Compliance 7 Avoid False Offshore Disclosure […]
Contents1 Taxpayers Advocate Service (TAS) Foreign Penalty Update2 What Is the Problem?3 What Is the Solution?4 Late Filing Penalties May be Reduced or Avoided5 Current Year vs Prior Year Non-Compliance 6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Need Help Finding an Experienced Offshore Tax […]
Contents1 A Guide to Legally Moving Money Offshore2 First, Moving Money Offshore is Not Illegal3 Also, Beware of the U.S.’ Worldwide Income Tax Implications4 Hiding Money Offshore: Legal vs Illegal5 Accounts in Hard-to-Reach Countries6 Intentionally Not Reporting the Money7 Offshore Asset Protection Trusts 8 International Reporting Requirements9 […]
Contents1 The Top 7 Criminal Tax Questions About Foreign Reporting Answered2 If I Missed Foreign Account Reporting, Will I Go To Jail?3 Is an IRS Quiet Disclosure a Crime?4 Is Unfiled FBAR a Crime5 Are Willful FBAR Violations a Crime6 Does the IRS Prosecute for FATCA […]
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 Late Filing Penalties and Fines May be Reduced or […]
Contents1 Was Your IRS Offshore Disclosure Denied? (2024 Update)2 Aggressive Certifications are Not Necessary3 Willfulness, But Sorry4 Willful, But Not Sorry (aka Fraud)5 Taxpayer Was Already Penalized for the Same Foreign Assets6 The Taxpayer Did Not Pay the Streamlined Penalty7 Current Year vs Prior Year Non-Compliance […]
Contents1 Common Streamlined Filing Compliance Mistakes to Avoid2 First, Is Your Attorney/EA Really an Offshore Disclosure Specialist?3 Properly Analyzing the Willfulness/Non-Willfulness Issue4 Overwriting the 14653 and 146545 Including Exempt Assets in the Penalty Computation6 Not Responding to Further IRS Inquiries7 Timing the Streamlined Submission8 Foreign […]
Contents1 The IRS Scrutinizes Foreign Account Reporting 2 Foreign Account Reporting vs Income-Generating3 Which International Tax Forms to File?4 Foreign Account and Form Examples5 Bank Accounts6 Securities Accounts7 Employment Pension Account (Treaty vs Non-Treaty)8 Personal Pension/Retirement Account or Scheme9 Foreign Life Insurance 10 Penalties for Late and […]
Contents1 An IRS Expatriate Audit Case Study2 Were Your Expatriation Tax Documents Accurate?3 What About Delaying the Exit Tax Payment?4 Expatriation Examination5 Section 965 Repatriation Tax6 Form 54717 Form 3520/3520-A8 Foreign Trust Distribution or Gift9 What Happens if Jennifer is Considered a Covered Expatriate?10 Foreign Pension11 […]
Contents1 Bad Tax Preparer Advice Gets Clients in Trouble2 The Buck Stops with the Taxpayer Client3 Foreign Accounts and Assets Case Study Example4 David Meets with a New CPA5 David’s CPA Has An Ulterior Motive6 David Does His Research7 An Important Fork in the Road8 The […]
Contents1 The IRS Warns About Offshore Bank and International Schemes2 Tax Promotions in General3 Hiding Assets Overseas4 Fraudulent Conveyances to Third Parties5 Moving Crypto Offshore to Avoid Taxes6 International Mixing of Cryptocurrency7 Misusing Foreign Trusts8 Falsifying Expatriation Documents9 Puerto Rico Act 6010 Late Filing Penalties May be […]
Contents1 The IRS Scrutinizes Abusive Trusts 2 Increased IRS Scrutiny of Trusts3 First, What is an Abusive Trust Scheme?4 Section 643(b) Trusts5 Offshore Asset Protection Trust (OAPT)6 Malta Retirement Scheme7 Charitable Remainder Annuity Trust (CRAT)8 What Forms are Required to Report a Foreign Trust?9 Do Any Foreign […]
Contents1 What You Must Know About Penalties for Form 3520-A2 Standard Form 3520-A Penalties3 Continuing Form 3520-A Penalty4 Potential Criminal Penalties5 Reasonable Cause May Abate/Avoid Form 3520-A Penalties6 Late Filing Form 3520-A Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid […]
Contents1 Malta Pension Plans are Being Targeted for IRS Non-Compliance2 First, Why The IRS Dislikes Malta Retirement Schemes3 New Malta CAA, Summonses, and Audits4 Potential Malta IRS Reporting Penalties (FBAR, FATCA, and More)5 Malta Retirement Scheme Example: Meet Michelle6 FBAR Penalties7 Form 8938 Penalties8 Form 3520/3520-A […]
Contents1 The IRS Cracks Down on Promoters of Abusive Sham Trusts2 Tax Seminars to Sell the Trust Promotion3 Three Sham Trusts and a Private Family Foundation4 Clients Remain as the Trustees5 Business Trust (Trust One)6 Second Trust and Third Trust7 Donation Into a Private Family Donation8 […]
Contents1 Taxpayers with Overseas Accounts2 Multiple Forms for the Same Foreign Account3 Different Thresholds for Different Forms4 Not all Due Dates and Filing Deadlines are the Same5 Exceptions and Exclusions May Apply6 Penalties and Abatement7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs […]
Contents1 Overview of Form 8938 Reporting2 Who Has to File Form 8938?3 What are the Form 8938 Threshold Requirements?4 What is the Form 8938 Due Date?5 What Types of Foreign Assets are Reportable?6 What if Form 8938 is Filed Late (Penalties)7 The Tip of the Iceberg8 […]
Contents1 IRS Form 3520 Beginner’s Guide: Foreign Gifts, Trusts & Inheritances2 The Purpose of Form 35203 Form 3520 Foreign Gift4 Form 3520 Foreign Inheritance5 Form 3520 Trust Distribution6 Form 3520/3520-A Ownership of Foreign Trust7 Related Persons8 Trust Reporting Exceptions (2020-17 and Proposed Regulations)9 The Tip […]
Contents1 How Much Did the IRS Really Ease Foreign Trust Reporting2 Increased Disclosure of Foreign Gifts Transferors3 No Deficiency Procedures Means No Advanced Notice to Taxpayers 4 Reasonable Cause is Still a Steep Climb5 Still Big Hurdles for Some Taxpayers Wanting to Comply6 Joint and Several Liability7 […]
Contents1 IRS Foreign Account Penalty Relief2 SFCP (Streamlined Filing Compliance Procedures)3 SDOP (Streamlined Domestic Offshore Procedures)4 SFOP (Streamlined Foreign Offshore Procedures)5 DFSP (Delinquent FBAR Submission Procedures)6 DIIRSP (Delinquent International Information Return Submission Procedures)7 VDP (Voluntary Disclosure Program)8 RC (Reasonable Cause)9 Avoid Making a Quiet Disclosure […]
Contents1 Avoiding IRS Abusive Schemes, Transactions and Arrangements2 First, Tax Fraud vs Tax Avoidance3 Malta Pension Plans/Retirement Schemes4 Foreign Trusts5 Syndicated Consideration Eastment/Art Contributions6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs […]
Contents1 Tax-Favored Foreign Retirement Account2 First, Why is Reporting Tax-Favored Foreign Retirement Trusts Hard?3 The IRS Has Power to Suspend 3520/3520-A Requirements4 Not a Reportable Event5 Definition of a Tax-Favored Foreign Retirement Trust6 Tax-Favored Foreign Retirement Trust Exceptions7 Why Exempt Tax-Favored Foreign Retirement Trusts?8 Not […]
Contents1 Understanding Foreign Gift Anti-Avoidance Rules2 Definition of “Foreign Gift” and coordination with section 6048(c)3 Proposed §1.6039F-1(b)(2)4 Late Filing Penalties May be Reduced or Avoided5 Current Year vs Prior Year Non-Compliance 6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Need Help Finding an Experienced […]
Contents1 The New Proposed Foreign Trust Regulations 2 $100,000 Gift to Adjust for COLA3 Additional Information About the Transferor4 Dual-Status Definition of a U.S. Person5 Migration of Foreign Trust to Domestic is a Distribution6 Limited U.S. Agent Status to Avoid Harsh Tax Consequences7 Late Filing Penalties […]
Contents1 For U.S. Resident Owners/Beneficiaries of Foreign Trusts 2 Example of Foreign Trust Ownership3 Which IRS Tax Forms to File?4 Trust Filing Exceptions5 A Non-Grantor Trust Beneficiary6 A Grantor Trust Beneficiary7 A Few Foreign Trust Issues to Consider8 U.S. Trust with Foreign Assets9 Throwback Rule10 Revenue Procedures […]
Contents1 D.C. App. Reverses Farhy, Rules Foreign Information Penalties Valid2 Are the Penalties Assessable?3 The Court Rules they are Assessable4 Late Filing Penalties May be Reduced or Avoided5 Current Year vs Prior Year Non-Compliance 6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Need Help Finding […]
Contents1 Form 3520-A Filing Requirements & Reporting Rules2 First, The IRS Does Not Like Foreign Trusts3 When is Form 3520-A Due?4 Can You Apply for an Extension?5 Appointing a U.S. Agent and Form 3520-A6 Foreign Grantor Trust Owner Statements7 Foreign Grantor Trust Beneficiary Statements8 Foreign Pension […]