No Clawbacks for Gifts if Estate Tax Exemption Changes
Lifetime gift giving can be an effective estate planning strategy for high net-worth clients. Although the estate tax is imposed on the aggregate of the taxable estate and lifetime taxable gifts, gifting removes the appreciation and cash flow of the
Foreign Proprietorship: Form 8858 Filing Requirement
US taxpayers with an ownership interest in unincorporated foreign businesses (such as foreign sole proprietorships, partnerships, and single-member entities that are not separately taxed as corporations) must file a Form 8858 with their regular 1040 income tax return. IRS Form
IRS announces two new intriguing targeted enforcement campaigns
Every so often the Internal Revenue Service announces a new “campaign” to increase tax compliance. A campaign usually means additional IRS focus and resources are allocated to the areas where the IRS is trying to improve compliance. The IRS recently
President Trump Revamps the IRS through his 2019 Taxpayer First Act
President Trump recently signed the Taxpayer First Act (TFA) of 2019, which for the first time in decades, will dramatically restructure, modernize and (hopefully) improve the Internal Revenue Service. There are several ways the new taxpayer-friendly law will reform the
Start or review an “Accountable Plan”
Accountable Plans, established under IRS Reg. Section 1.62-2(c)(4), are important tools to help a business optimally classify expenses paid to employees without fear of the payments being treated as taxable compensation. The 2017 law known as the Tax Cuts and
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
The new Post OVDP Compliance enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a result, they suggested the campaign.
New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance
Last week, the Internal Revenue Service began sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly. “Taxpayers should take
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
The new Loose Filed Forms 5471 targeted enforcement campaign was identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely received many Loose Filed Forms 5471 that were not properly filed, as a result, the suggested the
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
The new Offshore Private Banking enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting offshore bank accounts, as a result, they suggested the campaign.