A Lesson From Brown v. U.S.: A Defective Tax Refund Filing
The recent case from the U.S. Court of Appeals for the Federal Circuit in Brown v. the U.S. shows the detriments to Taxpayers who do not properly file their returns with the IRS in order
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
A recent decision from the District Court of Northern California has created more questions in the tax community about FBAR penalties. Usually, in challenging FBAR penalties, courts conclude that the US taxpayer will pay willful
How to Avoid Criminal Prosecution Through Voluntary Disclosure
The Voluntary Disclosure Practice is an IRS-created option of the IRS Criminal Investigations for U.S. Taxpayers at risk for criminal prosecution due to a tax-related offense. Taxpayers who have willfully failed to submit tax information
All the Many FBAR Late Filing Procedures
The FBAR or Foreign Bank and Financial Account Reporting or FinCen Form 114 is a form which many U.S. taxpayers are unaware and unfamiliar with and thus many of them become noncompliant and delinquent. However
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
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
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
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
Beware of Currency Seizures
In the past two decades, the US Department of Homeland Security (DHS) seized over $2 billion in currency at airports mostly due to travelers’ failure to fill out the relevant form. There is no limit
Our Best Net Investment Income Tax (NIIT) Tax Minimization Planning Strategies
The NIIT is a 3.8 percent Medicare surtax imposed on the lesser of an individual’s (a) net investment income (NII), or (b) the amount of modified adjusted gross income (MAGI) that exceeds $250,000 for MFJ
Watered-Down Build Back Better (BBB) For High-Income Taxpayers
After months of negotiations, the Democratic-led House of Representatives advanced the Build Back Better (BBB) Act to the Senate. The table below shows how the tax provisions have evolved since September. Many of the most
Charitable Planning Strategies High-Net-Worth Individuals Need to Know for Year-End Tax Planning
This year has a few charitable tax law changes unique to 2021. We have compiled our top charitable tax planning ideas you may want to consider implementing this year before December 31st. 1. Take advantage