US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more
Investment Advisers - ANNUAL COMPLIANCE REVIEWS - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level are required to review their compliance policies and procedures...more
With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more
Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax...more
The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more
Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that...more
As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more
The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more
On July 21, 2016, the Ninth Circuit in United States v. Hom, No. 14-16214 D.C. No. 3:13-cv-03721-WHA (9th Cir. 2016), determined that a taxpayer who held an online poker account with PokerStars and PartyPoker was not required...more
Overview - It is an understatement to say that the state of affairs in the offshore landscape is in flux. The fallout from the recent scandal in Panama remains to be seen. The fall of the rich and famous may end up...more
Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more
The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more