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…
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…
Contents1 FBAR vs 89382 What are the Foreign Account Offshore Reporting Laws?3 FBAR (FinCEN 114)4 FATCA & 89385 Are you out of FBAR or 8938 Compliance?6 Golding & Golding (Board-Certified Tax Law Specialist) FBAR vs 8938: Comparing IRS Offshore Account Filing Rules: The FBAR vs FATCA Form 8938 is (unnecessarily) complex. The IRS provides some…
Contents1 FBAR Insurance Policy 2 How to File an FBAR for Foreign Life Insurance3 Unreported Foreign Life Insurance Policy? FBAR Insurance Policy and how to report foreign life insurance to the IRS: The IRS FBAR Insurance rules for reporting life insurance for foreign policies are very complex. The IRS requires U.S. person owners of a foreign life…
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…
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….
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…
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…
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…
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…
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…
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…
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…
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…
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…
