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 well-structured trust is often a central estate planning tool for small businesses and closely held family business owners when passing a business or wealth to your children. This includes heirs, beneficiaries, and future...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
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
The United States Fifth Circuit Court of Appeals lifted the injunction imposed by a U.S. District Court in Texas on December 23, 2024. As a result, January 13, 2025 is the new deadline for FinCEN’s BOI Report for the vast...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Time Extensions
Why is the end of the year a good time to consider trust and estate planning for business owners? Do you own real property or have other investments outside your business interests? Have you given any thought to what would...more
12/19/2024
/ Asset Management ,
Beneficiaries ,
Business Ownership ,
Business Strategies ,
Business Succession ,
Creditors ,
Estate Planning ,
Investment ,
Life Insurance ,
Privacy Laws ,
Probate ,
Real Estate Investments ,
Revocable Trusts ,
Tax Planning ,
Trusts ,
Wills
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
There is important news regarding the Beneficial Owners Interest (BOI) report based upon a recent District Court decision in Texas. In the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., Case No. 4:24-cv-478,...more
12/12/2024
/ Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Deadlines ,
Department of Justice (DOJ) ,
Financial Reporting ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Texas ,
Unconstitutional Condition
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
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
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
Integrative legal, tax, accounting, and business advisory services are more critical than ever as we address the challenging environment of continuous change. Seek change; wherever you find it, opportunity will exist....more
11/15/2024
/ Accounting ,
Affordable Care Act ,
Alternative Minimum Tax ,
Business Advice ,
Business Development ,
Business Ownership ,
Business Strategies ,
Corporate Taxes ,
Deregulation ,
Foreign Policy ,
Tariffs ,
Tax Cuts and Jobs Act ,
Tax Reform ,
United States-Mexico-Canada Agreement (USMCA)
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