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New GTO covers Wire Transfers

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more

After the Storm: Forensic Accounting = Record Reconstruction

IRS is authorized to grant certain relief that may help Taxpayers and Businesses recover financially from the impact of a disaster when the federal government declares their location to be a major disaster area. IRS could...more

Greedy Charitable Deductions May Cost You

Taxpayers are not required to pay a negligence penalty for underpayment of income taxes if, under Internal Revenue Code regulations, there is reasonable cause for a position that the Taxpayer takes in an income tax return. ...more

Watch out if you are an Expatriate US Passport Holder with Tax Debt and receive Notice CP-508C!

According to the US Department of State, there are approximately nine (9) Million US passport holders living overseas. There continues to be a misimpression by certain US Taxpayers living overseas that they are not required...more

Out of Compliance Taxpayers: Beware of new IRS-Programs!

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more

The OECD is focused on maintaining the integrity of the CRS

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53...more

Does investing in a PFIC make sense given FATCA reporting?

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more

Mayweather vs. McGregor – is it about the FIGHT or is it about the TAXES? Or the Passport?

Much has been published concerning Floyd Mayweather’s Federal Tax Liens in the amount of $22.2 Million and an unpaid 2010 IRS debt of $7.2 Million. The Jasminebrand.com released on 7/21/17 that a $3.3 million federal lien has...more

8/24/2017  /  IRS , Sports , Tax Debt , Tax Liens

FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?

In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. ...more

Cumplimiento Fiscal Internacional

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

DVD can be an option for a Taxpayer without foreign financial accounts or foreign financial issues. It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much as...more

Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more

Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule

Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

Is your Bookkeeper the Right One?

Bookkeepers are by practical definition business multi-taskers. They keep financial records, post debits and credits, prepare reports, execute banking transactions, act as collectors for overdue accounts, work with clients...more

IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%. Nonetheless, IRS has its eye on the “collections” ball. The Agency has recently benefited from...more

6/26/2017  /  Income Taxes , IRS , Tax Debt , Tax Liability

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Indications of Misappropriation Schemes

Misappropriation is the use of property or funds of another person for an unauthorized purpose and is classified as a felony. In misappropriation, the perpetrator steals or misuses an organization’s belongings and resources;...more

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are...more

Is IRS really knocking at your door?

Generally, IRS sends a letter or a notice via regular mail notifying a Taxpayer of a potential visit. Nonetheless, IRS may also show up unannounced at the Taxpayer’s home or place of business....more

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

Employee Business Expenses must be Ordinary and Necessary

Employees may be able to deduct their work related expenses as an itemized deduction. These expenses must be unreimbursed expenses that are ordinary and necessary to their work as an employee. According to IRS, an ordinary...more

Debit cards, Offshore Funds and a John Doe Summons

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

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