New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers

The IRS quietly created new procedures for Streamlined Filing Compliance Procedures earlier this month relating to filings with “transition tax” due under Internal Revenue Code Section 965. The new procedures apply to Streamlined Domestic Offshore submissions and Streamlined Foreign Offshore

Unfiled FBAR Penalties Survive Death

Do FBAR penalties survive death? According to a new court ruling, the answer is clearly yes (unfortunately). In United States v. Gill, 2021 U.S. Dist. LEXIS 12203 (S.D. Tex. 6/30/21), the court ultimately held that an FBAR nonwillful penalty survives

FBAR Deadline Automatic Extension

All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or signatory authority over foreign bank and

Solution: Streamlined Domestic Offshore Procedures

In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are

Dormant foreign corporations not subject to complicated Form 5471 filing requirements

The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules.  However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. Although not widely published, IRS Revenue Procedure

Happy Birthday Streamlined Filing Compliance Procedure

The Streamlined Filing Compliance Procedure (SFCP) was “born” six years ago.  Six years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets. SFCP has two sub-programs: one

What is a SLAT?

While a slat is commonly known as a thin, narrow strip or bar of wood or metal, a SLAT is also known to estate planning professionals as a Spousal Lifetime Access Trust (SLAT). With the current lifetime estate and gift

New Form 3520 Penalties

In November 2020, the IRS changed the rules for assessing penalties for Form 3520, the Annual Return to Report Receipt of Foreign Gifts. Form 3520 is filed for any U.S. Taxpayer who receives a foreign gift or inheritance totaling over