After the closing of the Offshore Voluntary Disclosure Program (OVDP) - which ended on September 28, 2018, the US Department of Treasury released a Memorandum on November 20, 2018, disclosing an “Updated Voluntary Disclosure...more
The National Taxpayer Advocate 2017 Report to Congress states that the Accuracy-Related Penalty under Internal Revenue Code Section 6662 remains the number one most litigated tax issue and has been over the last four years. ...more
For Tax Year 2018, Taxpayers will use the new and re-designed Form 1040. Although the IRS’s sentiment is that many Taxpayers will only need to file Form 1040 and none of the NEW NUMBERED SCHEDULES, there will be Taxpayers...more
1/25/2019
/ Alternative Minimum Tax ,
Child Tax Credit ,
Filing Requirements ,
GILTI tax ,
Income Taxes ,
IRS ,
Required Forms ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Returns
El 30 de octubre del 2018, la división Internacional y de Grandes Empresas del IRS (“LBI”) anunció la aprobación de una campaña de cumplimiento que incluye cómo las Instituciones Financieras Extranjeras (“FFIs)) y ciertas...more
On October 30, 2018, the IRS Large Business and International division (LBI) announced the approval of a compliance campaign regarding Foreign Financial Institution (FFI) and certain Non-Financial Foreign Entity reporting of...more
The IRS TAX CRIMES HANDBOOK states that there are two kinds of tax evasion: (a) the willful attempt to evade or defeat the ASSESSMENT of a tax, and (b) the willful attempt to evade or defeat the PAYMENT of a tax. ...more
In the US, Taxpayers “self-assess and voluntarily” pay taxes. The IRS position is that Voluntary Compliance occurs when a Taxpayer makes a “good faith” effort to meet the Taxpayer’s tax obligations as defined in the Internal...more
An Individual Taxpayer Identification Number (ITIN) is a tax processing number issued by the IRS to foreign nationals and others who have federal tax reporting or filing requirements and do not qualify for Social Security...more
An IRS Audit is designed to be an impartial review to assess tax return filing accuracy. IRS selects returns for audit to determine the reporting accuracy of income, expenses, and/or refundable credits. ...more
The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more
9/14/2018
/ Bitcoin ,
Bitcoin Mining ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
FDAP ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
La posesión de moneda virtual, también conocida como criptomoneda, es legal tanto en los EE.UU como en muchas otras partes del mundo. La forma más conocida de moneda virtual es Bitcoin. ...more
9/6/2018
/ 1099s ,
Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
FATCA ,
FBAR ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
There are times when Taxpayers will attempt to use the “it is not my fault” argument as a defense relating to IRS penalties. Taxpayers might argue that they relied on guidance from a tax professional or from a tax software...more
Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more
6/11/2018
/ Corporate Taxes ,
Disregarded Entities ,
Filing Requirements ,
Foreign-Owned Corporations ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Reporting Requirements ,
Required Forms ,
Tax Liability ,
Tax Planning ,
Tax Returns
There are Individuals out there that are US Citizens (“Americans”) and they are not aware of it. Under US Tax Law, these individuals have US tax reporting responsibilities and tax obligations. These Individuals are known as...more
If you are a US citizen or a Permanente Resident and you live abroad, you are taxed on your worldwide income and you are considered a US Taxpayer. ...more
During 2017, 245 million tax returns were processed by the IRS and more than $3.4 trillion in federal taxes was paid by individuals and businesses to the US Treasury. ...more
To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns. Taxpayers want to make sure that their returns are processed correctly by the IRS. ...more
4/13/2018
/ 401k ,
Capital Gains ,
Charitable Deductions ,
Digital Currency ,
Filing Requirements ,
Foreign Bank Accounts ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Retirement Plan ,
Tax Deductions ,
Tax Planning ,
Taxable Distributions
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more
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
1/15/2018
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Foreign Ownership ,
IRS ,
Reporting Requirements ,
Required Forms ,
Tax Planning ,
U.S. Treasury
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
12/27/2017
/ 1099s ,
Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Fair Market Value ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Popular ,
Reporting Requirements ,
Section 6662 ,
Section 6722 ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
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
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
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
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
6/19/2017
/ Bank Secrecy Act ,
Banking Sector ,
FATCA ,
FBAR ,
Filing Requirements ,
Foreign Bank Accounts ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Memorandum of Understanding ,
OVDP ,
Tax Penalties
The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are...more
5/31/2017
/ Common Reporting Standard (CRS) ,
Exchange of Information ,
FATCA ,
Filing Requirements ,
IGAs ,
Information Sharing ,
IRS ,
Limited Liability Company (LLC) ,
OECD ,
Recordkeeping Requirements ,
Tax Treaty ,
TIEA