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If IRS wants to obtain records held in another country, Don’t ignore its request!

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982...more

Tenga cuidado con las Ventas o Transferencias del 10% de la Propiedad en una Corporación Extranjera

La "Ley de reducción de impuestos y empleos" (la "Ley") contiene una provisión que es una "acompañante hermana" de la Deducción por Dividendos Recibidos (DRD) que implica ventas o transferencias que envuelven un 10% de la ...more

Beware of Sales or Transfers of 10% ownership in a Foreign Corporation

The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign...more

¿Sabía usted que la "Ley" tiene una Deducción por Dividendos Recibidos (DRD)?

La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...more

La habilidad del IRS de negar o revocar los Pasaportes de los Contribuyentes con deudas fiscales significativas es uno de los...

El Departamento de Estado de los EE.UU esta requerido a denegar la solicitud de pasaporte de un individuo y está autorizado a revocar o limitar un pasaporte existente si el IRS certifica que el individuo tiene una deuda...more

Did you know that the “Act” has a Deduction for Dividends Received (DRD)?

The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...more

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

Conflict of Interest: When professional judgement is compromised….

Conflicts of interest can arise at any time during a professional engagement. According to the American Institute of Certified Public Accountants (AICPA), “A conflict of interest may occur if a member performs a...more

The IRS's ability to deny or revoke the Passports of Taxpayers with significant tax debts is one of the Most Serious Problems...

The U.S Department of State is required to deny an individual’s passport application and is authorized to revoke or limit an existing passport if the IRS has certified that the individual has seriously delinquent federal tax...more

¿Será la pregunta para el año 2017: ¿tiene cuentas financieras extranjeras?

Desde la crisis financiera mundial que comenzó en el 2007, los contribuyentes Estadounidenses e Internacionales han estado bajo un escrutinio creciente. El sistema financiero ha sido fuertemente regulado y monitoreado de...more

Will the question for the Year 2017 be: Do you have Foreign Financial Accounts?

Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax...more

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

Why are US Citizens Renouncing their Citizenship?

A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more

Bitcoins and the IRS: Reporting and Storing

Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that...more

Will Bankers = Law Enforcers on 5/11/18?

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more

Many are now looking for IRS Guidance on Virtual Currency

Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

What you need to know about Tax Court

The US Tax Court is a Federal trial court established by Congress. It is independent from the IRS. The mission of Tax Court is to resolve disputes between Taxpayers and IRS. Tax Court has the authority to provide rulings on...more

Pass-Through Treatment: Don’t bite the hand that feeds most Americans!

According to the U.S. Bureau of Labor Statistics, the Professional and Business Services (PBS) industry sector accounted for 12.9% of jobs in the U.S. during 2016 as opposed to 7.9% for the Manufacturing Sector (MS). The...more

Do you know which Business Structure to choose when starting a New Business?

When opening a new business, electing a business structure is an important decision. The business structure elected can affect how much will be paid in entity income taxes, record-keeping requirements, how much personal ...more

Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more

The Accountant and the Paradise Papers

Under U.S. Tax Law, it is appropriate for an Accountant to advise a US Taxpayer regarding his tax efficiency if the Taxpayer wants to pay less tax and accumulate wealth. While tax avoidance is legal and encouraged by the...more

Here is what you need to know about IRS proposed draft of Form 1040 for 2017

As a courtesy to Taxpayers, IRS provides an “early release draft” of an IRS tax form. The drafts are not to be used for filing, but are generally released when most changes have been incorporated into the Form. The...more

Is your spouse having trouble with the IRS and you didn’t know?

In a joint tax return filing, IRS has the right to assess both spouses that sign a joint income tax return under the penalty of perjury. This is similar to jointly signing for a loan at a Bank. The Bank will impose a legal...more

US Persons and Financial Institutions: Beware when engaging financially with Venezuela

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela. The transactions that are prohibited by US Persons apply wherever a US...more

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