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
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