How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
6/16/2025
/ Disclosure Requirements ,
Expatriates ,
FBAR ,
FinCEN ,
International Tax Issues ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more
5/27/2025
/ Business Entities ,
Disclosure Requirements ,
Filing Requirements ,
Foreign Corporations ,
International Tax Issues ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion ,
Tax Liability ,
Trusts
Have you been asked to be a trustee or executor? A trustee or executor has substantial financial and legal liability, and the trust or estate will pay an attorney to guide them through the process....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
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
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
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
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
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
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
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 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
Have you forgotten about the Beneficial Ownership Information (BOI) Report established by the Corporate Transparency Act (CTA) of 2021? Owners of qualifying domestic entities, as well as those qualifying foreign entities...more
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
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
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
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
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