Mitchell Horowitz

Mitchell Horowitz

Buchanan Ingersoll & Rooney PC

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Deadline: Foreign Bank Account Reports Due June 30, 2016

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

6/15/2016 - FBAR FinCEN Foreign Bank Accounts Foreign Financial Assets

New Partnership Audit Rules Will Require Amendment of All Partnership Agreements by 2018

On November 2, 2015, Congress passed the Bipartisan Budget Act of 2015, Section 1101 of which repeals the long-standing current rules for IRS audits of partnership entities and replaces those rules with a new centralized...more

5/11/2016 - Audits Bipartisan Budget IRS Partnership Agreements Partnerships

Passport May Be Revoked If Owing More Than $50,000 in Taxes

On December 4, 2015, the Fixing America’s Surface Transportation Act (the FAST Act) was signed into law. Among other items, the FAST Act gives the Internal Revenue Service (IRS) and the Department of the Treasury power to...more

2/9/2016 - Fixing America’s Surface Transportation Act (FAST Act) IRS Passports Tax Debt

Updates on Offshore Financial Account Compliance and Small Business Audit Considerations

Recently, IRS officials, including Commissioner John Koskinen, have stated that the streamlined filing program for the disclosure of previously unreported foreign financial accounts would not last forever and would end at...more

1/27/2016 - FBAR FinCEN Foreign Financial Accounts IRS Small Business

Possible Changes to IRS Audits of High Income Individuals

The Internal Revenue Service (IRS) is considering increasing the income threshold to identify a taxpayer as being wealthy enough to be audited by the IRS’s High-Income and High-Wealth Strategy Team. The recommendation to do...more

12/13/2015 - Audits High Net-Worth Income Taxes IRS

Changes in Tax Return and FBAR Due Dates and Extensions

The deadline for filing tax returns and Foreign Bank Account Report (FinCEN Form 114) (FBAR) has been changed by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Below is a brief summary of...more

11/4/2015 - C-Corporation FBAR FinCEN Partnerships S-Corporation Surface Transportation and Veterans Health Care Choice Improvement Act Tax Extensions Tax Returns

Innocent Spouse Relief Granted Due to Spousal Abuse Even If Requesting Spouse Had Knowledge of Tax Deficiency

In a recent Tax Court case, innocent spouse relief was granted to a Florida taxpayer to relieve her from over $400,000 in tax deficiency and penalties. Tax Court typically is reluctant to grant innocent spouse relief when the...more

9/3/2015 - Income Taxes Innocent Spouse Exception Joint Tax Returns Remedies

$10,000 in Cash Receipts? Heightened Penalties for Failure to File Form 8300 Within 15 Days

Any person who, in its trade or business, receives cash in the amount of more than $10,000 in a single transaction or a series of related transactions must file Form 8300, Report of Cash Payments Over $10,000, Received in a...more

7/22/2015 - Bank Secrecy Act Cash Transactions Criminal Penalties Failure-to-File FinCEN IRS

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

7/7/2015 - Corporate Taxes Foreign Nationals Foreign Trusts IRS Offshore Funds Tax Penalties Tax Returns Trusts

IRS New Guidance Significantly Reduces Maximum FBAR Penalties

To moderate the draconian Foreign Bank and Financial Accounts (FBAR) violation penalties under Title 31 of the U.S. Code, the IRS just published guidance that significantly reduces willful and non-willful FBAR violations....more

6/26/2015 - FBAR Foreign Bank Accounts Foreign Financial Assets IRS New Guidance Penalties Willful Violations

June 30 Deadline: Foreign Financial Account and Asset Reporting Obligations

Do you maintain bank accounts outside the U.S.? Do you own any foreign financial assets, such as foreign stock or a loan to a foreign person? If you do, you should be aware that you may have extra reporting obligations to the...more

6/22/2015 - FBAR FinCEN Foreign Bank Accounts Foreign Entities Foreign Ownership Reporting Requirements

Innocent Spouse Relief and Recent Guidance

Generally, when you and your spouse file joint income tax returns, the law makes both you and your spouse responsible for the entire tax liability. This is called joint and several liability. Both spouses remain 100 percent...more

6/15/2015 - Federal Taxes Income Taxes Innocent Spouse Exception IRS Joint and Several Liability Joint Tax Returns

DEADLINE: Foreign Bank Account Reports Due June 2015

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

5/18/2015 - FBAR Filing Deadlines FinCEN U.S. Treasury

IRS’s Offshore Voluntary Disclosure Program: Current Streamlined Procedure

U.S. citizens and tax residents are required to report their world-wide income on their federal income tax returns. In addition, these U.S. persons are required, and have been required for some time, to separately report...more

7/17/2014 - IRS Offshore Funds OVDP Reporting Requirements

Deadline: Foreign Bank Account Reports Due June 30, 2014

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

5/2/2014 - FBAR FinCEN Offshore Banks Offshore Funds Reporting Requirements U.S. Treasury

Florida Revised Limited Liability Company Act: The Power to Bind the LLC

The new Florida Revised Limited Liability Company Act (the “New Act”) became effective on January 1, 2014 for all limited liability companies (“LLCs”) formed in the State of Florida on or after January 1, 2014. The New Act...more

2/18/2014 - Binding Corporate Rules Compliance LLC

Florida Revised Limited Liability Company Act: The Operating Agreement

In May, 2013, the Florida legislature passed into law the new Florida Revised Limited Liability Company Act (the “New Act”) which becomes effective on January 1, 2014 for all limited liability companies (“LLCs”) formed in the...more

9/18/2013 - LLC New Legislation Operating Agreements

Florida Revised Limited Liability Company Act: Management

As described generally in our recent article “Florida’s New Revised Limited Liability Company Act”, the Florida legislature passed the new Florida Revised Limited Liability Company Act (the “New Act”) which becomes effective...more

8/20/2013 - Limited Liability Act LLC New Legislation

Federal Income Tax Implications of Supreme Court Decision United States v. Windsor

The U. S. Supreme Court’s decision in United States v. Windsor, 570 U.S. ___ (2013) implicates important changes to the interpretation and administration of federal tax laws (including, income, gift and estate taxes). On June...more

8/13/2013 - DOMA Estate Tax Federal Taxes Gift Tax Income Taxes Marriage Same-Sex Marriage SCOTUS US v Windsor

Florida’s New Revised Limited Liability Company Act

On June 14, 2013, Governor Rick Scott signed into law the new Florida Revised Limited Liability Company Act (the “New Act”). The New Act is codified in new Chapter 605 of the Florida Statutes and, as of January 1, 2015, will...more

7/17/2013 - LLC New Legislation Operating Agreements Rick Scott

Deadline: Foreign Bank Account Reports Due June 30, 2013

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

6/11/2013 - Electronic Filing Foreign Bank Accounts Foreign Banks U.S. Treasury

Avoiding the Documentary Stamp Tax

Documentary Stamp Tax: Pursuant to §201.02, Florida Statutes, subject only to a few specifically enumerated exceptions beyond the scope of this article, documentary stamp tax is due on instruments conveying an interest in...more

1/10/2013 - Documentary Stamp Tax Real Estate Transfers

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