Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more
Is it too soon for a BOI report obituary? After a recent declaration by the U.S. Department of Justice, the FinCEN Beneficial Ownership Interest reporting requirements may be a thing of the past for American companies....more
Attention: FinCEN BOI reporting requirement deadline is now set for March 21, 2025.
A decision yesterday, February 18, 2025, in the case of Smith, et al. v. U.S. Department of Treasury, et al., 6:24-cv-00336, has returned...more
2/20/2025
/ Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Requirements ,
FinCEN ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
U.S. Treasury
It has always been prudent to search for firms who can integrate legal, tax, accounting and business advisory services. While there are few such genuine providers across the United States they do exist, and the KPMG Arizona...more
2/20/2025
/ Accounting ,
Arizona ,
Business Entities ,
Compliance ,
Corporate Governance ,
Estate Planning ,
Financial Services Industry ,
Integration ,
Popular ,
Small Business ,
Tax Planning ,
Taxation
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
1/23/2025
/ Anti-Money Laundering ,
Beneficiaries ,
Compliance ,
FACTA ,
FBAR ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Trusts ,
Grantor Trusts ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Trusts
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
1/21/2025
/ C-Corporation ,
Compliance ,
Double Taxation ,
FinCEN ,
Foreign Corporations ,
Foreign Investment ,
GAAP ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Planning ,
Tax Treaty
UPDATE: DECEMBER 28, 2024: In the latest twist of the FinCEN Beneficial Owners Information (BOI) report, the new deadline for FinCEN's BOI Report is on hold again....more
1/3/2025
/ Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Reporting Requirements ,
Reversal ,
Vacated
What risks are associated with a lack of due diligence during a business acquisition, asset purchase, stock purchase, or merger? How can due diligence make or break the success of any mergers and acquisitions transaction? ...more
Internal Revenue Service Criminal Investigation (IRS-CI) recently released its Fiscal Year 2024 (FY24) Annual Report, providing insight into the types of crimes the agency is focused upon, as well as the first criminal...more
12/18/2024
/ Annual Reports ,
Artificial Intelligence ,
Compliance ,
Criminal Convictions ,
Criminal Investigations ,
Crypto Exchanges ,
Cryptocurrency ,
Cyber Crimes ,
Data Processing Rules ,
Digital Assets ,
IRS ,
Law Enforcement ,
Money Laundering ,
Popular ,
Settlement ,
Tax Evasion
Hopefully, by now, you’ve become aware of the Beneficial Ownership Information Form, commonly referred to as the BOI Form or BOI Report. The Financial Crimes Enforcement Network (FinCEN) finalized rules for this report late...more
12/5/2024
/ Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Final Rules ,
FinCEN ,
Government Agencies ,
Law Enforcement ,
Limited Liability Partnerships ,
Limited Partnerships ,
Noncompliance ,
Penalties ,
Reporting Requirements ,
SBA ,
Trusts
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
11/27/2024
/ Compliance ,
Duty to Report ,
FBAR ,
Filing Requirements ,
FinCEN ,
Income Taxes ,
Investigations ,
IRS ,
Reporting Requirements ,
Tax Audits ,
Tax Avoidance ,
Tax Evasion ,
Tax Penalties ,
Tax Returns ,
Transparency ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
11/20/2024
/ Amended Tax Returns ,
Artificial Intelligence ,
Attorney-Client Privilege ,
Audits ,
Compliance ,
Constitutional Safeguards ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
FBAR ,
Fees ,
FinCEN ,
Fines ,
Foreign Financial Institutions (FFI) ,
Immunity ,
Income Taxes ,
Investigations ,
IRS ,
Offshore Funds ,
Penalties ,
Tax Evasion ,
Transparency ,
Voluntary Disclosure ,
Willful Misconduct
It's human nature to take the "if it ain't broke, don't fix it" attitude, which extends to allowing areas of your business to evolve and develop without scrutiny. This is why tuning up your business is an essential part of...more
11/20/2024
/ Accounting ,
Business Advice ,
Business Development ,
Business Income ,
Business Operations ,
Business Strategies ,
Compliance ,
Corporate Governance ,
Corporate Veil ,
Creditors ,
Data Collection ,
Decision-Making Process ,
Investors ,
Legal Advice ,
Liability ,
Limited Liability Company (LLC) ,
Reporting Requirements ,
Shareholders ,
Small Business ,
Supply Chain ,
Tax Planning ,
Vendors
What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more
10/15/2024
/ Audits ,
Compliance ,
Cryptocurrency ,
Disclosure Requirements ,
Filing Requirements ,
Income Taxes ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Penalties ,
Voluntary Disclosure
What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit?
How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more
9/25/2024
/ Audits ,
Capital Gains Tax ,
Compliance ,
Fees ,
Filing Requirements ,
FinCEN ,
IRS ,
Liability ,
Statute of Limitations ,
Tax Penalties ,
Tax Returns
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more
6/19/2024
/ Audits ,
Compliance ,
Enforcement ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Partnerships ,
S-Corporation ,
Tax Deductions ,
Tax Loopholes ,
Tax Rates ,
Tax Returns ,
Transfer of Assets
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more
5/30/2024
/ Audits ,
Compliance ,
FACTA ,
FBAR ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
IRS ,
Offshore Funds ,
Personal Information ,
Social Security Numbers ,
Voluntary Disclosure
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
What is the importance of year-end corporate governance work? I know. I can see and hear it now: most businesspeople just roll their eyes and ask, “why do I have to go through this hassle?” What is the purpose of a corporate...more
12/15/2023
/ Asset Management ,
Business Litigation ,
C-Corporation ,
Compliance ,
Corporate Governance ,
Liability ,
Limited Liability Company (LLC) ,
Operating Agreements ,
Piercing the Corporate Veil ,
S-Corporation ,
Succession Planning
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS?
In...more
12/13/2023
/ Artificial Intelligence ,
Audits ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FATCA ,
FBAR ,
FinCEN ,
Fines ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Partnerships ,
Swiss Banks ,
Tax Fraud ,
Tax Returns
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
11/28/2023
/ Audits ,
Automated Systems ,
Business Losses ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Data Processors ,
E-Filing ,
FATCA ,
FBAR ,
Financial Institutions ,
FinCEN ,
Investors ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Penalties ,
Perjury ,
Reporting Requirements ,
Retirement ,
S-Corporation ,
Software ,
Tax Credits ,
Tax Deductions ,
Tax Fraud ,
Tax Preparers ,
Tax Returns ,
U.S. Treasury
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
11/16/2023
/ Advance Health Care Directive ,
Alternate Investment Vehicles (AIVs) ,
Beneficiaries ,
Capital Gains Tax ,
Compliance ,
Documentation ,
Estate Planning ,
Expatriates ,
FBAR ,
FinCEN ,
Foreign Banks ,
Foreign Financial Accounts ,
Grantors ,
Income Taxes ,
Investment Portfolios ,
IRS ,
Life Insurance ,
Living Will ,
Mutual Funds ,
Passive Investments ,
Power of Attorney ,
Probate ,
Property Owners ,
Retirement Plan ,
Risk Mitigation ,
Tax Deductions ,
Tax Planning ,
Trusts