The TCJA and the Future of American Taxpayers

Our article on the new tax law was published today by the American Bar Association below… https://www.americanbar.org/groups/gpsolo/publications/gpsolo_ereport/2018/june-2018/tcja-future-american-taxpayers.html The TCJA and the Future of American Taxpayers Vol. 7, No. 11 Parag Patel and Anannya Tripathy Parag Patel, Esq., is a tax attorney in

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).

IRS reminds those with foreign assets about U.S. tax obligations

The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take notice and become compliant. The

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

IRS Issue Number:    IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program

FBAR statute of limitations court case ruling

In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR forms from 2006 through 2008.

The 65-Day Rule: What Every Trustee Should Know about Taxes

Happy New Year!  With the close of the calendar year behind us, tax season is just beginning for individuals and many entities.  If you are serving as the trustee of a complex trust, however, it’s not too late to take

Some FBAR Deadlines Extended

Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain

IRS Advisory: Prepaid Real Property Taxes May Be Deductible in 2017 if Assessed and Paid in 2017

The Internal Revenue Service advised tax professionals  today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The new tax law signed last week in Washington prohibited the deduction of prepaid

New 2018 Tax Law’s Business Tax Changes

President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week.  The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,

New 2018 Tax Law’s Individual Tax Changes: New Tax Brackets, Credits and Deductions

President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week.  The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,

4 tax strategies before Jan. 1 to lower your tax bill under the new tax law

  Give more to charity in 2017. Have you been meaning to donate? If so, get it done by year’s end. It helps reduce your income this year when tax rates are higher. Plus, you might not end up itemizing

IRS Announces New international campaigns

On November 3, 2017, the IRS announced an additional 11 compliance campaigns as areas of focus for the Large Business & International Division (“Announcement”). The 11 newly identified campaigns focus primarily on international issues, with seven international campaigns and four

IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do

An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax

Beware IRS Forms W-8

Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign non-US entities or persons (citizens and corporations) in order to

Powerful Post-death Planning Strategies for Trusts and Estates

After a client passes away, there is much more to do than just prepare a final Form 1040, U.S. Individual Income Tax Return. Taking control of the postmortem planning process can be a powerful way to save tax dollars for

IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party

The long awaited revised IRS Form W8-BEN has been recently released in July  2017.  The major changes to IRS Forms W8, particularly W-8BEN-E (which is still in draft form), have been driven by the changes in the law under FATCA. The new IRS

Complicated Form 5471 filing requirements simplified for dormant foreign corporations

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. IRS Revenue Procedure 92-70, specifies specific, conditions

U.S. Tax Court: What to Expect

Reasons to Take Your Matter Before the United States Tax Court: You’ve recently undergone an audit or examination. You have taken the proper administrative steps to argue your case but still receive a notice of deficiency or notice of determination