201804.23
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OVDP Closes on 9/28/2018 – 5 Important Facts About OVDP Ending

OVDP Closes on 9/28/2018 – 5 Important Facts About OVDP Ending OVDP is the traditional Offshore Voluntary Disclosure Program. OVDP (formerly OVDI) has been in existence since 2009, and the IRS has accumulated more than $9 billion of money from taxpayers who have entered the program in order to safely get into compliance. OVDP is Coming…

201804.18
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FBAR Willfulness Lower Threshold (2018) – IRS Ends OVDP on 9/28

FBAR Willfulness Lower Threshold (2018) – IRS Ends OVDP on 9/28 The IRS continues to tighten the noose around anybody caught willfully failing to report or disclose foreign accounts or income. This is very important for any individual who may have willfully (even recklessly aka Reckless Disregard) failed to report foreign accounts, assets, income, or…

201804.16
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Multi-Jurisdictional Tax Compliance – IRS Reporting & Reasonable Cause

Multi-Jurisdictional Tax Compliance – IRS Reporting & Reasonable Cause Unfortunately, trying to be in compliance with U.S. Tax Law while not violating Foreign Tax Law(s), is a very real problem. When a new client contact us with this type of situation – we sincerely understand the severity and stressfulness of the issue. In a typical…

201804.13
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Form 8938 Threshold (2018) – IRS Penalties for Non-Compliance

Form 8938 Threshold (2018) – IRS Penalties for Non-Compliance Form 8938 is similar to the FBAR (Report of Foreign Bank and Financial Account Form), but it is more comprehensive and actually much more dangerous. Why? Because with the FBAR, a person is simply reporting their foreign accounts and the form itself is not filed alongside…

201804.11
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FinCEN 114 (FBAR) Filing is on Automatic Extension in 2018

FinCEN 114 (FBAR) Filing is on Automatic Extension in 2018 Recently, we had a client contact us in hysterics. She was freaking out, because she just finished an initial consultation with one of the self-proclaimed “Experts” in Offshore Disclosure and a Former IRS Attorney… He told her she needed to pay him money ASAP in order…

201804.11
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2018 IRS Dirty Dozen – Danger of Offshore Money & OVDP Ending

2018 IRS Dirty Dozen – Danger of Offshore Money & OVDP Ending Each year the IRS identifies 12 of the worst tax scams to be cautious of when it comes to investing your money, and/or other related activities. And, each year one of the 12 almost always includes offshore tax scams. Offshore Tax Enforcement The IRS has…

201804.09
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IRS Criminal Tax Investigations (2018) – The End of OVDP | Penalty Risk

IRS Criminal Tax Investigations (2018) – The End of OVDP | Penalty Risk For many years, individuals, businesses and estates that knowingly or recklessly (aka willfully) evaded paying tax on foreign income, or did not report foreign accounts, assets, or investments to the IRS had a get out of jail free card – OVDP. But, with the…

201804.06
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International Tax Implications of Divorce (2018) – IRS Penalty Risks

International Tax Implications of Divorce (2018) – IRS Penalty Risks When spouses divorce, and assets include offshore or foreign accounts, investments, or other income from abroad — there are various tax, and penalty implications to be aware of. International Tax Divorce During our many years of practice, we have come across several instances where one…

201804.04
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PFIC Tax – First Year Distributions vs. First Distribution

PFIC Tax – First Year Distributions vs. First Distribution PFIC is an acronym for “Passive Foreign Investment Company.” As far as tax reporting goes, a PFIC is one of the more complicated aspects of international tax. Mainly, because the term PFIC is very nebulous and not properly defined. Moreover, it is very encompassing, and once…

201804.02
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Increased Risk of IRS International Tax Prosecution & Penalties (2018)

Increased Risk of IRS International Tax Prosecution & Penalties (2018) In the last year, much has happened with international tax law and the IRS. First, the IRS developed more than 20 new tax enforcement groups — many of which were designed exclusively to curtail tax fraud, tax evasion and money laundering of international money. In addition, the IRS set…

201803.30
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How the IRS Uncovers Offshore Tax & Reporting Violations (2018)

How the IRS Uncovers Offshore Tax & Reporting Violations (2018)  One of the most common questions we receive is “How will the IRS find my foreign accounts?” This is a legitimate question, because quite frankly…why bother getting into compliance with the IRS, if the IRS is never going to find you. Prior to FATCA (Foreign…