Search Results for: non-willful
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.
…reported, and the potential liability of the taxpayer and tax preparer. We will discuss solutions for non-compliant taxpayers. Experienced tax attorney Parag Patel has handled hundreds of foreign asset disclosures…
IRS attempts to demystify its new Form 8938
…You do not need to separately report the assets of a financial account on Form 8938, whether or not the assets are issued by a U.S. person or non-U.S. person….
Charitable Planning Strategies High-Net-Worth Individuals Need to Know for Year-End Tax Planning
…up to 100% of your AGI. Any contributions over 100% of your AGI will be carried forward for use in a future year. Non-cash contributions made in 2021 will not…
Eleven foreign financial institutions to share their US customer account information
…accounts around the world. As they describe it, the “top litigation priority is the concerted civil and criminal effort to combat the serious problem of non-compliance with our tax laws…
Watch Out: IRS Audits of ERC Claims Expected
…had over a certain number of employees in 2019, you could only claim the credit if you paid furloughed (non-working) employees. If you were under the threshold, you could claim…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
…easing paperwork requirements to allow individuals more flexibility to get non-streamlined Installment Agreements up to $250,000 without financial verification, if their case is not yet assigned to a revenue officer….
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…offshore bank accounts, as a result, they suggested the campaign. The IRS Post OVDP Compliance enforcement campaign goal is to improve return selection, identify issues representing a risk of non-compliance,…
New 2018 Tax Law’s Individual Tax Changes: New Tax Brackets, Credits and Deductions
…nonrefundable credit for non-child dependents. State and local taxes: In a controversial provision, the TCJA limits the deduction for state and local income taxes (SALT) to $10,000 annually for any…
FATCA Deadlines Extended
Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued…
65 Day Election on March 6, 2023
…12% bracket. As part of this analysis, the fiduciary must also consider the 3.8% Additional Medicare Tax, as well as non–tax factors such as the financial acumen of the beneficiary…
Increase in the annual gift tax exclusion to $14,000
…But if you give your daughter $10,000 in December and wait to hand over the other $10,000 until January 1, both gifts are tax-free. Giving Away Non-Cash Property Not only…
Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”
…must be aware of the risks in each available program, as the sanctions imposed on taxpayers that willfully fail to disclose are incredibly harsh. Counsel must first evaluate whether the…
US real property now more attractive for certain foreign investors
…also abolish an additional tax imposed by FIRPTA on qualifying foreign pension funds that invest in US real estate. The exemption for Regulated Investment Company (RIC) dividends paid to non-resident…
What is a “FATCA Compliance Certificate”?
…instances of delinquent or failure to file tax returns. Most importantly, noncompliant persons must clean up their noncompliance mess before the government finds them, after which it is too late….
Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)
…(“CSRA”) The Community Spouse Resource Allowance (“CSRA”) is the amount of non-exempt resources (owned jointly or separately by either spouse) that the law permits the community spouse to retain without…
How to Stretch Your IRA Into a Family Fortune
…each. Traps… If an IRA with multiple beneficiaries isn’t split up, the life expectancy of the oldest governs distributions for the others. If a non-person (such as a charity) is…
IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements
…information exchange is part of the IRS’s overall efforts to implement FATCA, enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts or foreign entities. FATCA…
10 Costly Mistakes to Avoid in Helping Families with Special Needs
…or after the client’s death. COSTLY MISTAKE #2: Procrastination.Because none of us knows when we may die or become incapacitated, it is important that your clients plan for a beneficiary…
Family Limited Partnerships, or more commonly now, Family Limited Liability Companies, are great vehicles for management & protection of family assets
…the necessary criteria. 1. Were timely and properly filed papers filed to set up an FLP under appropriate state law? 2. Has the planning team carefully documented the significant non-tax…
IRS’ New “Dirty Dozen” list of tax scams
…continuing surge of fake emails, text messages, websites and social media attempts to steal personal information. Scams targeting non-English speakers: IRS impersonators and other scammers also target groups with limited…
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…accounts at offshore private banks. This campaign addresses tax noncompliance and the information reporting associated with these offshore accounts. The IRS will initially address tax noncompliance through audit examination and…
India Expected to Sign FATCA Agreement Tomorrow
…persons connected to the U.S. Non-compliant financial institutions could be frozen out of U.S. markets and subjected to punitive withholding taxes. If a financial institution does not comply with FATCA,…
What is a Stretch IRA?
…is because the provisions of most trusts will not qualify as a flow-through trust. In contrast, should a non-qualified trust be named as the Designated Beneficiary, all the income tax…
PRESIDENT BUSH SIGNS THE HOUSING AND ECONOMIC RECOVERY ACT OF 2008 WITH TAX BENEFITS AND TRAPS FOR THE UNWARY
…by state and local governments. The new law gives non-itemizers a limited deduction for state and local real property taxes by increasing the amount of their standard deduction by the…
Family Limited Liability Companies (LLCs)
…to be equivalent to those of a “business” for the bona fide sale exception to be applicable. The Court stated that Mrs. Mirowski had “legitimate and significant non-tax reasons” for…
Top 4 Exceptions to FBAR Filing Requirement
…an individual who files an FBAR is not required to file a separate FBAR if (1) all the financial accounts that the non-filing spouse is required to report are jointly…
Deferral is the Name of the Game: Funding a Trust With Retirement Assets
…benefit. It is important to review your assets with your attorney to make sure your estate has the flexibility, to the greatest extent possible, to fund these trusts with non-retirement…
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
…risk of non-compliance, and make the greatest use of IRS limited resources. Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, must be attached to an…
Adding Beneficiaries to an Irrevocable Life Insurance Trust
…considered a non-reportable gift to the beneficiary under the ILIT. The remaining $37,000 could be divided up between four contingent beneficiaries who would be entitled to shares of the ILIT…
Watered-Down Build Back Better (BBB) For High-Income Taxpayers
…that are often utilized when valuing an interest in an entity that holds non-business assets; The imposition of investment restrictions on IRAs that would prevent retirement accounts from holding certain…