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Author: Parag Patel

Planning in the Time of Coronavirus

17 March, 2020

The coronavirus is an illness that we cannot ignore. Older adults are especially vulnerable and those who have an underlying issue such as diabetes, heart disease, and respiratory conditions. Many such individuals are in a

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IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A

4 March, 2020

A Revenue Procedure just released by the U.S. Internal Revenue Service (IRS) provides U.S. persons an exemption from the information reporting requirements for certain tax-favored foreign retirement and non-retirement savings trusts. Taxpayers who would otherwise

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Planning for Dependent (or not Independent) Family Members

2 March, 2020

One in four Americans has some form of disability. In our law firm’s client base, it is very common to have a family member that is not entirely able to live independently. Even worse, adults

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The IRS is Assessing Form 3520 Foreign Information Reporting Penalties

21 February, 2020

The IRS is aggressively sending out IRS Notice CP15 “Notice of Penalty Charge” for the late filing of Form 3520 to report the receipt of a foreign gift or foreign inheritance. The Notice states that

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 2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better

27 January, 2020

While we all resolve to go to the gym every day and lose weight, we have compiled a list of 2020 New Year’s tax planning resolutions. Beware of 2020 election-year tax uncertainties. It is important

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The InSECURITY of the SECURE Act

24 January, 2020

At the end of 2019, Congress passed the “Setting Every Community Up for Retirement Enhancement” (SECURE) Act of 2019. The new law, which represents a major overhaul of the rules for retirement plans and IRAs,

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Are You Ready For New FATCA Enforcement in 2020?

2 January, 2020

Banks and certain other financial institutions located outside the United States that have U.S. account holders are scrambling to meet a looming IRS deadline. These institutions, known as foreign financial institutions, or FFIs, must achieve

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No Clawbacks for Gifts if Estate Tax Exemption Changes

27 December, 2019

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

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Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court

19 December, 2019

  In the recent 2019 case U.S. v. Ram Agrawal, a US District Court rejected a taxpayer’s reasonable cause defense against foreign bank account reports (FBARs) penalties. It ruled in favor of the government to

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Foreign Proprietorship: Form 8858 Filing Requirement

6 November, 2019

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

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IRS announces two new intriguing targeted enforcement campaigns

12 September, 2019

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

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President Trump Revamps the IRS through his 2019 Taxpayer First Act

12 September, 2019

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

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