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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

New GTO covers Wire Transfers

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more

After the Storm: Forensic Accounting = Record Reconstruction

IRS is authorized to grant certain relief that may help Taxpayers and Businesses recover financially from the impact of a disaster when the federal government declares their location to be a major disaster area. IRS could...more

Greedy Charitable Deductions May Cost You

Taxpayers are not required to pay a negligence penalty for underpayment of income taxes if, under Internal Revenue Code regulations, there is reasonable cause for a position that the Taxpayer takes in an income tax return. ...more

Watch out if you are an Expatriate US Passport Holder with Tax Debt and receive Notice CP-508C!

According to the US Department of State, there are approximately nine (9) Million US passport holders living overseas. There continues to be a misimpression by certain US Taxpayers living overseas that they are not required...more

Out of Compliance Taxpayers: Beware of new IRS-Programs!

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more

The OECD is focused on maintaining the integrity of the CRS

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53...more

Does investing in a PFIC make sense given FATCA reporting?

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more

Mayweather vs. McGregor – is it about the FIGHT or is it about the TAXES? Or the Passport?

Much has been published concerning Floyd Mayweather’s Federal Tax Liens in the amount of $22.2 Million and an unpaid 2010 IRS debt of $7.2 Million. The Jasminebrand.com released on 7/21/17 that a $3.3 million federal lien has...more

8/24/2017  /  IRS , Sports , Tax Debt , Tax Liens

FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?

In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. ...more

Cumplimiento Fiscal Internacional

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

DVD can be an option for a Taxpayer without foreign financial accounts or foreign financial issues. It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much as...more

Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more

Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule

Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

Is your Bookkeeper the Right One?

Bookkeepers are by practical definition business multi-taskers. They keep financial records, post debits and credits, prepare reports, execute banking transactions, act as collectors for overdue accounts, work with clients...more

IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%. Nonetheless, IRS has its eye on the “collections” ball. The Agency has recently benefited from...more

6/26/2017  /  Income Taxes , IRS , Tax Debt , Tax Liability

FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the Bank Secrecy...more

Indications of Misappropriation Schemes

Misappropriation is the use of property or funds of another person for an unauthorized purpose and is classified as a felony. In misappropriation, the perpetrator steals or misuses an organization’s belongings and resources;...more

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