Search Results for: international tax
Estate Planning for 2021 and Beyond: SLATs
…tax. We have recently received unprecedented interest in SLATs due to President-elect Biden’s tax plans to raise estate taxes. Now is the time to explore SLATs before it’s too late….
Parag Patel Esq. presents new tax law changes at Broward Chapter of The Florida Society of Enrolled Agents (FSEABC) Webinar
…avoid. “Upcoming federal tax law changes: What to Expect” This presentation will bring tax professionals up-to-date on current issues in federal income taxation affecting individuals and small business owners with…
Make Sure You have Filed FATCA Compliance Certifications
…in full compliance with all US tax and reporting requirements to avoid future tax and legal problems. For example, US tax law requires annual information reporting on all Indian accounts…
Estate Planning in a Recession
…gift tax-free, to anyone you wish to assist immediately, rather than after your death. Annual gifting may also reduce your estate tax liability by removing assets from your estate during…
Consider a tax legal opinion to confirm clients’ 199A Specified Service Trades or Businesses (SSTB) status
On Aug. 8, 2018, the IRS released proposed regulations around the centerpiece provision of the Tax Cuts and Jobs Act. The new Section 199A tax deduction provides owners of sole…
Laws May Cause Issues for Owners In Civil Unions
…gift-tax exclusion. The $1 million lifetime federal gift-tax exclusion counts toward the federal estate-tax exemption, a tax levied upon death that is currently capped at $2 million but scheduled to…
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
IR-2015-09, Jan. 28, 2015 WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax…
The 65-Day Rule: What Every Trustee Should Know about Taxes
…taxed to the beneficiaries instead of to the trust) ultimately results in a tax savings between the trust and the beneficiaries. To manage the tax burden of a complex trust,…
The IRS’ Complex Statute of Limitations
…Taxpayers who are undergoing an audit or tax collection defense should contact Patel Law Offices. Over the years, our office has successfully assisted numerous taxpayers regarding their tax compliance issues….
IRS announces two new intriguing targeted enforcement campaigns
…illegal or improper for US taxpayers to own offshore structures, accounts, or assets. However, taxpayers must comply with income tax and information reporting requirements associated with these foreign activities, otherwise…
IRS Announces New Statistics Regarding Voluntary Disclosures
…June 2014. The streamlined filing compliance procedures, which is for non-willful taxpayers, require a 5% penalty for resident taxpayers and a 0% penalty for nonresident taxpayers. This IRS statistic is…
Charitable Planning Strategies High-Net-Worth Individuals Need to Know for Year-End Tax Planning
…result in tax savings. Be sure to work with your advisers now to evaluate your tax situation and take advantage of some of these strategies before December 31, 2021. Taxpayers…
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
…they have unreported income. See below quote: The Delinquent International Information Return Submission Procedures clarify how taxpayers may file delinquent international information returns in cases where there was reasonable cause…
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…
What is the U.S. tax on Inheritances from a Non-U.S. Person to U.S. Person?
…large fines. Three very common U.S. tax questions on receiving an inheritance from abroad: Do U.S. taxpayers pay tax on inheritance money from overseas? No. How much money can you…
2 recent IRS developments that will impact Indian Americans
…non-resident US taxpayers who have resided outside of the US since January 1, 2009 and who have not filed a US tax return during the same period. However, these taxpayers…
Correcting Common FBAR Errors
…requires a taxpayer to file eight prior years’ tax returns and FBARs, provide detailed information regarding any unreported foreign financial account(s), and pay all taxes, accuracy penalties, delinquency penalties, and…
Increased IRS Enforcement Expected Against High-Income Taxpayers
…a taxpayer who either does not timely file a required tax return and timely pay a tax due for the delinquent return. If contacted by the IRS, the taxpayer should…
Plan Now for Dynasty Trusts
…estate taxes until it reached its final recipient. Without using a Dynasty Trust, each generation would amass an estate tax to be paid. Rather than losing wealth on taxes, this…
Caution: Foreign Businesses Require Additional Reporting
…taxable person (U.S. citizens or U.S. green card holders) owns a controlling stake in a foreign business, that business is likely a Controlled Foreign Corporation (CFC) for U.S. tax purposes….
Asset Protection for Physicians
…to lose wealth is through bad marriages, bad investments, bad tax planning, or a combination thereof. The average physician usually can’t name a colleague who got cleaned out in a…
Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)
…Tax Court has simplified procedures for taxpayers whose amount in dispute, including applicable penalties, is $50,000 or less per tax year. You can find these simplified small tax case procedures…
Corporate Transparency Act (CTA) Reporting Company Analysis and FAQs
…of the loss of such tax-exempt status; (B) a political organization, as defined in section 527(e)(1) of the Code, that is exempt from tax under Section 527(a) of the Code;…
30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS
…tax. The taxpayer that wants to fight on can either pay the tax and sue for a refund in District Court, or file a petition for review in the Tax…
2009 Tax Update
A few things have changed with the coming of a new year—below are some tax items to be aware of. Estate and gift taxes: The basic federal estate-tax exemption increased…
Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?
…including extensions, of the electing person’s U.S. income tax return for the year. U.S. taxpayers should be clear when purchasing foreign mutual funds given the potentially detrimental tax treatment they…
Is the IRS Finally Receiving Increased Funding?
…business – we are closing tax loopholes and enforcing the tax code.” The Act, entitled “Enhancement of Internal Revenue Service Resources,” provides the following new IRS funding: Taxpayer Services: $3,181,500,000…
Malta pension plans listed on “Dirty Dozen” list of “tax scams”
Last week, the Internal Revenue Service (IRS) placed certain Malta-based pension plan arrangements on its annual “Dirty Dozen” list of “tax scams.” In its recent news release, the IRS warns…
Tax treaty tie-breakers
Under many US tax treaties, if a foreign individual is a tax resident of both the US and his home country then certain ‘tie breaker’ rules will apply to determine…
IRS Announces Major New changes to the Offshore Voluntary Disclosure Program
…taxpayers of their offshore tax obligations. “Through our enforcement efforts and implementation of FATCA, taxpayers are more aware of their obligations, and we believe want to come into compliance,” Koskinen…