One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
4/25/2025
/ Attorney-Client Privilege ,
Audits ,
Business Ownership ,
California ,
Estate Planning ,
FBAR ,
Foreign Investment ,
International Tax Issues ,
IRS ,
Offshore Banks ,
Tax Liability ,
Tax Planning
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more
3/27/2025
/ Beneficiaries ,
Business Succession ,
Estate Planning ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Probate ,
Small Business ,
Tax Planning ,
Tax Reform ,
Trusts
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
Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more
Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year?  A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more
2/12/2025
/ 1099s ,
eBay ,
Financial Transactions ,
FinTech ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lyft ,
Mobile Apps ,
Mobile Payments ,
PayPal ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Uber ,
Venmo
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
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
1/29/2025
/ Double Taxation ,
FBAR ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Tax Credits ,
Income Taxes ,
Investors ,
IRS ,
Mutual Funds ,
Offshore Banks ,
PFIC ,
Tax Credits ,
Tax Planning
Don't stick your head in the sand and miss important business or personal tax deadlines...more
1/28/2025
/ Business Taxes ,
California ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
State Taxes ,
Tax Planning ,
Tax Returns
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
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
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
Are you above the age of 50? Do you and/or your spouse have a 401(k)? Are you interested in reducing the amount you will have to pay in 2025 income taxes while increasing the amount of money you receive after retirement?...more
11/25/2024
/ 401k ,
Adjusted Gross Income ,
Employee Benefits ,
Employee Contributions ,
Income Taxes ,
Investment ,
IRS ,
Retirement Plan ,
Tax Credits ,
Tax Incentives ,
Tax Planning
We are often asked how to prepare for an IRS audit. The first and most important thing to know is that speaking directly with the IRS is not in your best interest. IRS Revenue Officers (auditors) are skilled interrogators....more
11/22/2024
/ Algorithms ,
Attorney-Client Privilege ,
Audits ,
CPAs ,
Financial Adviser ,
Interrogations ,
IRS ,
Statute of Limitations ,
Tax Avoidance ,
Tax Credits ,
Tax Deductions ,
Tax Revenues
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
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
11/14/2024
/ Appeals ,
Applications ,
Double Taxation ,
Expatriates ,
Foreign Tax Credits ,
France ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Investment Income ,
NIIT ,
Tax Liability ,
Tax Refunds ,
Tax Treaty
Have you come across the surprising IRS tax bracket changes for 2025? Yesterday, the IRS released the 2025 income tax brackets for U.S. taxpayers. The inflation adjustments to tax brackets were a pandemic-boosted 7% for...more
What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development?
Here is the short answer: If you...more
10/22/2024
/ Audits ,
Brokers ,
Cryptocurrency ,
Digital Assets ,
Financial Records ,
Infrastructure Investment and Jobs Act (IIJA) ,
Investigations ,
Investors ,
IRS ,
Penalties ,
Popular ,
Reporting Requirements ,
Safe Harbors ,
Tax Evasion ,
Trading Platforms ,
U.S. Treasury
The IRS digital asset broker reporting requirements were finalized earlier this year and impact all digital asset (i.e., cryptocurrency and Non-Fungible Tokens or NFTs) transactions beginning January 1, 2025. What do...more
10/21/2024
/ Brokers ,
Cryptocurrency ,
Digital Assets ,
Foreign Financial Institutions (FFI) ,
Infrastructure Investment and Jobs Act (IIJA) ,
Investment ,
Investors ,
IRS ,
New Regulations ,
Non-Fungible Tokens (NFTs) ,
Reporting Requirements ,
Tax Evasion ,
U.S. Treasury
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
The IRS extension deadline is in one week, Tuesday, October 15, 2024. This is the last date for most U.S. taxpayers with extensions to file their 2023 federal income tax return without incurring late filing fees and other...more
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
Many small business owners mistakenly believe business succession planning and estate planning is for those with substantial wealth. This is simply a myth which does not reflect the nature of business or home ownership....more
8/28/2024
/ Asset Protection ,
Beneficiaries ,
Business Ownership ,
Business Succession ,
Buy-Sell Agreements ,
Connelly v United States ,
Documentation ,
Estate Planning ,
Heirs ,
IRS ,
Probate ,
Redemption Agreement ,
S-Corporation ,
SCOTUS ,
Small Business ,
Succession Planning ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Valuation