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Category: Planning for Tax Minimization

New Court Case Limits the Reasonable cause exception to FBAR penalties

3 September, 2017

Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of

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

10 August, 2017

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

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New IRS practice unit: “Substantial compliance” doctrine, international information return penalties

29 June, 2017

The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties, particularly Form 5471. The IRS recently

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U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

19 June, 2017

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers

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FATCA Noncompliant Accounts may be Frozen or Blocked

9 May, 2017

Many of our clients with foreign accounts have received FATCA letters.  The letters seek personal information regarding the account holder in order to comply with the US FATCA law. In recent weeks, government authorities in

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Complicated Form 5471 filing requirements simplified for dormant foreign corporations

28 April, 2017

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

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U.S. Tax Court: What to Expect

26 April, 2017

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

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The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

18 April, 2017

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16

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India issues FATCA Self-certifications and KYC Warnings

17 April, 2017

The Government of India continues to crackdown on self-certifications and know your customer (KYC) compliance for financial accountholders. Earlier this month the government said that the account holders of any financial institutions need to provide

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IRS Issues Reminders for FBARs and other International Requirements

14 April, 2017

The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At the same time, the agency

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Using the 65-day rule as an opportunity for income tax savings for estate

24 March, 2017

One of the tax planning tools available to executors of estates is the 663(b) election, also known as the “65-day rule.” Simply put, a 663(b) election allows distributions made to beneficiaries within 65 days of

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New Jersey Department of Revenue publishes “Manual of Audit Procedures”

21 March, 2017

On March 7th, the New Jersey Department of Revenue released its “Manual of Audit Procedures” to the public, which is intended to provide a comprehensive overview of the procedures and guidelines available to it for

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