New Jersey Division of Taxation Now Issuing Letter Rulings
The New Jersey Division of Taxation recently announced that it will implement new procedures for taxpayers to obtain letter rulings. Similar to letter rulings issued by the Internal Revenue Service with regard to federal tax issues, letter rulings issued by
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
you should assume that the IRS will eventually be informed of your foreign account, and criminal prosecution for non-disclosure and non-reporting will likely follow
Abatement of the NJ Amnesty Non-Participation Penalty is Still Possible for Some Taxpayers
The Praxair (Praxair Technology, Inc. v. Director, Div. of Taxation, N.J. App. Div., Docket No. 4-6262-06T3 (Sept. 1, 2010) case involved a taxpayer that received its assessment prior to the start of amnesty. If you receive an assessment after amnesty
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
The New Jersey Department of Treasury, Division of Taxation announced today that it will offer a Second Voluntary Compliance program to complement the Internal Revenue Service Second Special Voluntary Disclosure Initiative to identify assets and unreported income from previously sheltered
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in 2009 and the new 2011 FAQs seem to resolve some
2011 Offshore Voluntary Disclosure Initiative (OVDI)
On February 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes.
IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution
After a successful indictment of a New Jersey man with HSBC Bank accounts in India, the IRS introduced a new Voluntary Disclosure Program on February 8, 2011 for U.S. taxpayers with undisclosed offshore accounts. Last week, according to an indictment
IRS Targets Non-Resident Indians with HSBC Accounts
HSBC, one of the largest banks international banks in the world, is facing rough time with allegations on its holding bankers being involved with a New Jersey Indian American businessman in hiding his bank accounts in India from the Internal
New voluntary disclosure program for offshore accounts in 2011
The IRS...described the new program as “somewhat similar” to the prior program.
Is HSBC the next UBS nightmare?
clients with a foreign HSBC account should be seriously concerned about disclosure of the account to the government, which could result in criminal prosecution and significant civil penalties.
NJ Division of Taxation Announces Conferences and Appeals Branch Initiative
In an effort to address the large backlog of cases awaiting an administrative hearing pursuant to N.J.S.A. 54:49-18, the NJ Division of Taxation recently announced its reallocating resources in order to increase the number of staff available to hold conferences.
Structuring: A Tax Crime
One of the most frequent criminal charges our firm encounters is the illegal structuring of cash transactions to evade the IRS reporting requirements of Section 6050I. Usually the taxpayers who break this law are not engaged in money laundering, the
Estate Tax Pitfalls Seen In Court Case
Few things get people madder at their estate planners than fights over who must pay taxes when someone dies. A big source of trouble: the patchwork of state rules that apply. Most states say those who inherit have to share
New offshore account disclosure law
To pay for the hiring incentives in the recently enacted “Hiring Incentives to Restore Employment Act” (the 2010 HIRE Act), Congress passed several offsetting revenue raisers, including a comprehensive set of measures to reduce offshore noncompliance by giving IRS new
Pennsylvania’s 2010 Tax Amnesty Program
Our firm recently successfully filed several client's state amnesty applications.
New York Penalty and Interest Discount (PAID) program
In the state's press release, they mention they are increasing their enforcement efforts to collect unpaid bills.
Foreign Account Tax Compliance Act – Traps for the Unwary
For anyone who has clients or family members that live and work abroad, the new Foreign Account Tax Compliance Act (FATCA) is a real problem. Although this Act is supposed to punish Americans who hide assets abroad to avoid their
What does divorce do to your estate plan?
According to census bureau statistics, nearly half of married couples will at some time go through a divorce. If you are going through the divorce process, you’ve got a lot of company. So, do you need a new will? What
Asset Protection
For the client who needs to protect assets, estate planning may include the use of asset protection trusts (such as foreign-situs trusts) that will put assets safely out of reach. Although there are potentially many reasons to use such vehicles,
A Good Time To Review Estate Tax Plans: Decline in asset value prompts new strategies
Now is a particularly good time for business owners to think about estate tax planning.
$3.5 Million Federal Estate Tax Exemption for 2009 Could Mean Higher State Death Taxes
If the federal exemption is greater than the state exemption, the difference may become subject to state death taxes.
Obama to Keep 2009 Estate Tax Level
President Obama wants to freeze the current estate tax level to $3.5 million which is the estate tax exemption amount for 2009.
How to Stretch Your IRA Into a Family Fortune
Your individual retirement account (IRA) can do much more than provide funds for your retirement — it can be stretched to provide millions of dollars in payouts to your children, grandchildren or others you choose to be beneficiaries. Example:
Stretch your IRA
How would you like to make your grandchildren millionaires? Would it put a smile on your face to insure that your great-grandchildren never have to think about money? Its easy … if you have the discipline and self control to
Laws May Cause Issues for Owners In Civil Unions
LGBT business owners in New Jersey should assemble a team comprised of a lawyer, an accountant and a financial adviser who are familiar with the laws surrounding same-sex couples.
The Secret Stretch IRA
It may seem like a contradiction, but there is a way to leave a lot of money to your heirs even if you’re not rich. Individual retirement accounts (IRAs) were established to let you save tax-deferred until age 70 1/2,
Estate Planning: More Than A Will
By Parag P. Patel, Esq.www.patellawoffices.com During our lifetime, most of us strive to create and build upon our net worth. We generate savings, purchase a home, and eventually invest in stocks, bonds, mutual funds, IRAs and retirement plans. Unfortunately, most
Estate Planning in New Jersey
Estate Planning in New JerseyYou can save a lot of money and potential chaos and hard feelings among those closest to you by preplanning how you want your assets managed when you are incapacitated, and how your property will be
Family Limited Liability Companies (LLCs)
As a proponent of Family Limited Liability Companies (LLCs) for asset management, creditor protection, and ease of gifting, I was pleased to read about the U.S. Tax Court’s decision in Mirowski v. Commissioner, T.C. Memo 2008-74. March 26, 2008. Mrs.