A Lesson to be Learned from US v. Schwarzbaum: Bring Back the Foreign Funds to Pay FBAR Penalties
The recent case of U.S. v. Schwarzbaum shows U.S. taxpayers the length the United States will go to require a U.S. person to pay FBAR penalties, to the point of requiring the taxpayer repatriate money located outside the United States
New US-Malta Agreement Targets Pension Planning by US Taxpayers
Last week, the United States and Malta signed a competent authority arrangement (CAA) confirming their understanding of the meaning of pension fund for purposes of the United States–Malta income tax treaty (Treaty). The competent authorities have entered into this agreement after
Beware IRS Letter 6291
Many of our clients have recently received IRS Letter 6291, which begins with Why We’re Contacting You: “Our records for the tax years above show you did not properly report the foreign financial accounts on form 8938 statement of specified
Do You Have to Pay US Taxes on Foreign Inheritance?
We get this question almost daily…A U.S. person owes no U.S income tax on the receipt of an inheritance or gift from an individual living outside the United States. However, there are important legal considerations to review, including the Foreign