Tax Relief for Strategic Investments
Investors in New Jersey are finally getting some well deserved tax relief for their strategic investments. A new law, signed by New Jersey Governor Christie earlier his year on January 31, 2013, revives and expands the expired “Small New Jersey-Based
Visited by IRS Special Agents?
IRS Special Agents are employed by the Criminal Investigation Division (CID) which is the law enforcement arm of the Internal Revenue Service (IRS). Special Agents conduct tax investigations that are intended to result in criminal prosecutions. They conduct criminal investigations
Opting Out of the Offshore Voluntary Compliance Initiative Programs
As with other IRS’ 2009 and 2011 offshore voluntary compliance initiatives, the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe that he or she should have to pay the 27½%
Increase in the annual gift tax exclusion to $14,000
The IRS recently increased the annual gift tax exclusion from $13k to $14K in 2013. The annual gift tax exclusion is the amount you and your spouse can each gift to anyone without dipping into your lifetime gift tax exclusion.
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
When a taxpayer has a tax increase though a civil tax audit (or examination, in IRS terminology), a taxpayer has the right to appeal that increase administratively and through court, if unsuccessful administratively. For taxpayers not willing to accept the
Pre-Immigration Income Tax Planning
Since the United States has some of the highest tax rates and most complex tax rules in the world pre-immigration tax planning is very important (but rarely done). Various actions that resident and nonresident aliens take can affect the amount
Important Provisions of the American Taxpayer Relief Act of 2012
On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012 (“Act”) which was signed into law on January 2, 2013. While certain provisions of the Act are considered to be “permanent”, an overhaul of the Internal Revenue
Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program
Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi urged U.S. clients to enter
Off the Cliff Commentary About the New 2013 Tax Law
As predicted, Congress waited until the last minute to make a deal, technically after we plunged off the fiscal cliff to pass a new tax law. The new 2013 tax law, in summary, is below with some of our commentary:
Uncertainty About The Future Of The Gift And Estate Tax Laws Will Continue
Even if Congress acts to avoid the “Fiscal Cliff,” uncertainty about the future of the gift and estate tax laws will continue. Despite this uncertainty, meaningful estate planning goals can be achieved. Estate planning is only partly about tax. Whatever
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs. As a result, we have succinctly summarized some of
Tax Planning Opportunities for High Net Worth Individuals
Despite the election results, taxes are going up! Although major tax law changes are set to take place in 2013, there are opportunities for high net worth individuals. Below are a few planning opportunities. Tax Provisions Which May Impact Planning Opportunities
Tax Planning Opportunities for Business Owners
Unless Congress acts quickly, taxes are going up! Although major tax law changes are set to take place in 2013, there are some planning opportunities for business owners: Tax Provisions Which May Impact Planning Opportunities ■ Federal estate tax exemption decreasing
New Tax Planning Opportunities for High Income Individuals
To help appreciate the planning opportunities individuals may have between now and year end, we have prepared a summary of the key tax law provisions affecting high income individuals. Tax Provisions Which May Impact Planning Opportunities ■ Marginal ordinary income
Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities
Unless Congress acts quickly, taxes are going up! Although major tax law changes are set to take place in 2013, uncertainty makes it hard for families and businesses alike to plan ahead. Below are the expected tax law changes: Marginal ordinary
IRS Notices for OVDI Program
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of the 2009 OVDP, the IRS now appears to be applying
Short Lived Planning Opportunities for the Rest of 2012
The current gift tax exclusion is scheduled to expire at midnight on December 31, 2012, bringing to an end the highest exemptions ever seen. Under current law for 2012, each person has the ability to gift or dispose of assets