Out of Tax Compliance to both the U.S. & Foreign Tax Authorities?

Contents1 U.S. & Foreign Tax Non-Compliance 2 Double the Risk3 Dangers of Undisclosed Accounts, Multiple Countries4 Foreign Country with No Offshore Disclosure Program5 Streamlined or Reasonable Cause6 Compliant with Foreign Country Tax, But Not the IRS7 Non-Compliance in Multiple Countries8 Streamlined or Reasonable Cause is No Longer an Option9 Manafort is Typical, Even if the Amount of…


IRS Special Agent – IRS Offshore Money | 3 Examples of Whistleblowing

Contents1 IRS Special Agents2 Important “Special Agent” Terms2.1 IRS Criminal Investigation2.2 Tax Fraud or Tax Evasion2.3 Offshore2.4 IRS Offshore Voluntary Disclosure3 Warning4 Who are the Special Agents?5 How the IRS Learns About Your Mis-Dealings?5.1 Scott and His Girlfriend5.2 Michelle Was Not Very Nice to her Staff5.3 Peter’s Business Partner Feels Slighted6 Why Do Special Agents…


Form 8621 Instructions – Summarizing The Basics to IRS Reporting

Contents1 Form 86212 Do You Have a PFIC?3 What is a PFIC?3.1 Income Test3.2 Asset Test4 What is the Threshold for Reporting?5 How Do I Report The PFIC?5.1 Step 1: How Many PFICs Do You Have?5.2 Step 2: Determine the PFIC Values5.3 Step 3: Basic Filer Information5.4 Step 4: Summarizing the PFIC5.5 Step 5: What is…


U.S. Entrepreneurs with Foreign Income or Accounts – International Tax

Contents1 U.S. Entrepreneurs & International Tax 2 Worldwide Income3 Important Foreign Account & Asset Definitions3.1 Foreign3.2 Account3.3 Reporting3.4 FBAR3.5 TD 90.22-13.6 FinCEN Form 1143.7 BSA4 Foreign Accounts5 Foreign Assets6 Tax Treaties7 Totalization Agreements8 Already Out of Compliance?9 Getting into Compliance10 1. OVDP 10.1 What is Included in the Full OVDP Submission?10.2 OVDP Penalties11 2. Streamlined Domestic Offshore Disclosure11.1 What am…


FBAR (2018) – Important Tips for Timely Reporting Accounts to the IRS

Contents1 FBAR 2 Important FBAR Definitions2.1 Foreign2.2 Account2.3 Reporting2.4 FBAR2.5 TD 90.22-12.6 FinCEN Form 1142.7 BSA3 How to File The Form4 Step 1 – Are you a U.S. Person?5 Step 2 – Do You Meet the Threshold Requirements?6 Step 3 – Identify What is an Account7 Step 4 – How Many Accounts Do You Have?8…


International Trust IRS Reporting Rules – U.S. Tax, Assets & Accounts

Contents1 The Grantor May Still Be Taxed2 Form 3520-A Reporting3 Does the Trust Have Foreign Accounts?4 Be Proactive, Get Into Compliance with Offshore Disclosure5 Penalties5.1 The following is a summary of penalties as published by the IRS on their own website:5.2 FBAR 5.3 Form 89385.4 Form 35205.5 Form 3520-A5.6 Form 54715.7 Form 54725.8 Form 9265.9…


IRS Criminal Investigation – 5 Key IRS Tax Investigation Techniques

Contents1 IRS Criminal Investigation2 Contacting Your Bank Manager3 Showing up at Your Home, Unannounced4 Showing up at your Employment or Place of Business5 Sudden Stopping of Communication From the IRS6 Interviewing your CPA7 Danger of Non-Compliance8 Avoid these Issues with IRS Offshore Disclosure9 Penalties9.1 The following is a summary of penalties as published by the IRS on…


Quiet Disclosure IRS vs. Streamlined Disclosure (2017-2018 Review)

Contents1 Quiet Disclosure vs. Streamlined Offshore 2 What is a Quiet Disclosure?3 Anatomy of a Typical Quiet Disclosure 4 The Problem: Now You Are Willful5 Quiet Disclosure vs. Streamlined 5.1 Quiet Disclosure5.2 Streamlined Program6 Streamlined Domestic Offshore Procedures7 Streamlined Foreign Offshore Procedures8 Streamlined Domestic Penalty Calculation9 Streamlined Program – Common Examples10 What Forms Must be Reported?11 Reporting Foreign Accounts (FBAR)12…


Form 8938 Instructions – Important Steps to Reporting Foreign Assets

Contents1 Form 8938 Basics1.1 First Determine if You Have to File1.2 Make a List of your Foreign Assets1.3 Determine the Value of the Foreign Assets1.4 Exclude Assets That Are Not Included in the Analysis1.5 Determine the Income Generated from the Assets1.6 Determine Whether your Assets are Deposit or Custodial1.7 Be Sure to Identify Question 3 of…