The InSECURITY of the SECURE Act
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,
Are You Ready For New FATCA Enforcement in 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
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
Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court
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
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
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
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
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
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
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
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
Details of the Streamlined Foreign Offshore Procedures (SFOP)
Many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are a number