Connelly v. Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as...more
8/12/2024
/ Business Succession ,
Buy-Sell Agreements ,
Closely Held Businesses ,
Connelly v United States ,
Estate Tax ,
Fair Market Value ,
IRS ,
Liability ,
Life Insurance ,
Redemption Agreement ,
Right of Redemption ,
SCOTUS ,
Tax Audits
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
7/16/2024
/ Artificial Intelligence ,
Cryptocurrency ,
Disclosure Requirements ,
FBAR ,
Foreign Bank Accounts ,
Foreign Financial Institutions (FFI) ,
IRS ,
Negligence ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Returns ,
Taxable Income ,
Willful Misconduct ,
Willful Violations
What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more
Are you selling items online or receiving payment for goods and/or services on platforms such as PayPal, Venmo, eBay, Zelle, Etsy, or Cash App? Online platforms are the preferred method of shopping for most Americans. These...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
6/28/2024
/ Artificial Intelligence ,
Audits ,
Business Ownership ,
FBAR ,
FinCEN ,
Foreign Investment ,
IRS ,
Partnerships ,
Perjury ,
S-Corporation ,
Tax Forms ,
Tax Returns
It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California...more
6/26/2024
/ Appeals ,
Artificial Intelligence ,
Audits ,
Buy-Out Agreements ,
California ,
FACTA ,
Federal Taxes ,
Foreign Financial Institutions (FFI) ,
Investigations ,
IRS ,
Liquidation ,
State Taxes
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required...more
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
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
5/31/2024
/ Bank Accounts ,
Capital Gains Tax ,
Conflicts of Interest ,
Criminal Prosecution ,
Cryptocurrency ,
EU ,
Expatriates ,
FACTA ,
FBAR ,
FinCEN ,
Fines ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
International Financial Reporting Standards ,
International Tax Issues ,
Investment ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Evasion
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 are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more
5/17/2024
/ Beneficial Owner ,
Expatriates ,
FACTA ,
Foreign Financial Institutions (FFI) ,
GAAP ,
Income Taxes ,
Investment ,
IRS ,
Mutual Funds ,
Offshore Funds ,
Passive Foreign Investment Company
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
5/16/2024
/ Artificial Intelligence ,
Audits ,
FACTA ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Bank Accounts ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Penalties ,
Voluntary Disclosure
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
5/13/2024
/ Amended Tax Returns ,
Artificial Intelligence ,
FBAR ,
Financial Institutions ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Code ,
Tax Evasion ,
Tax Returns ,
Voluntary Disclosure
In a recent notice the IRS is reminding all of us to undertake planning to protect important documents in the event of a natural disaster. This is National Wildfire Awareness Month, and we are in the midst of National...more
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
4/30/2024
/ Disclosure Requirements ,
Failure-to-File ,
FBAR ,
Financial Crimes ,
FinCEN ,
Income Taxes ,
Investment ,
IRS ,
Money Laundering ,
Mutual Funds ,
Noncompliance ,
Offshore Banks ,
Penalties ,
Popular ,
Terrorism Funding
In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more
The sunset of the TCJA – the Tax Cuts and Jobs Act of 2017, is currently scheduled for the end of 2025. The TCJA contributed substantial changes to the US tax code that have benefited many US taxpayers. How should a US...more
4/19/2024
/ Business Strategies ,
Estate Planning ,
Income Taxes ,
Investors ,
IRS ,
Legislative Agendas ,
Strategic Planning ,
Tax Code ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
Tax Returns
Do you employ an irrevocable trust or trusts as part of your estate plan? You need to review your irrevocable trust to ensure it still delivers the benefits intended. It is generally possible to modify an irrevocable trust,...more
4/17/2024
/ Asset Protection ,
Beneficiaries ,
Capital Gains Tax ,
Estate Planning ,
Estate-Tax Exemption ,
Grantors ,
Heirs ,
Irrevocable Trusts ,
IRS ,
Medicaid ,
New Rules ,
Step-Up Basis ,
Veterans' Benefits
An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
3/27/2024
/ Audits ,
Bank Accounts ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FBAR ,
Financial Institutions ,
FinCEN ,
Fines ,
Foreign Assets ,
Foreign Nationals ,
GAAP ,
Investment ,
IRS ,
Offshore Banks ,
Penalties ,
Real Estate Investments ,
Swiss Banks
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
What is known as the IRS survivor’s penalty, and is there anything that can be done to provide for a surviving spouse as we age? The “survivor’s penalty” is the likelihood that a surviving spouse will face higher federal and...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers?
The value of many...more
3/19/2024
/ Cryptocurrency ,
Digital Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Treasury