Search Results for: international tax
IRS Issues Reminders for FBARs and other International Requirements
…cases, affected taxpayers need to complete and attach Schedule B to their tax return. Part III of Schedule B asks about the existence of foreign accounts, such as bank and…
Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
…whose gross receipts for a taxable year are $20 million or less. Taxpayers should review their previously filed returns and consult with their tax advisors as necessary to determine whether…
Forms 3520, 5471 and 5472 Penalty Relief
In IRS Notice 2022-36, the IRS granted relief from certain failure-to-file penalties and certain international information return penalties for most individual and business taxpayers who did not file tax returns…
Top 4 Exceptions to FBAR Filing Requirement
…with hundreds of clients regarding their FBAR compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. …
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
…with hundreds of clients regarding their offshore compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our…
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….
HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS
…Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to…
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is…
IRS delinquent FBAR submission procedure
…will not be automatically subject to audit but may be selected for audit through the existing audit selection processes that are in place for any tax or information returns. http://www.irs.gov/Individuals/International-Taxpayers/Delinquent-FBAR-Submission-Procedures…
10 Most Frequently Asked Questions and Answers for Stretch IRAs
…beneficiaries. Until recently, IRA assets were usually liquidated shortly after the beneficiary’s death. This put an end to tax deferral and often resulted in large taxable distributions. Thanks to a…
Now is the time to explore a Spousal Lifetime Access Trust (SLAT)
With the upcoming election and potential tax law modifications based on the outcome, high net worth married couples should consider meeting with their advisors to determine what they can do…
What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?
…value at the end of each taxable year, recognizing any gain or loss for that year. Under the mark-to-market election, the taxpayer is required to include in their taxable income…
A Good Time To Review Estate Tax Plans: Decline in asset value prompts new strategies
…to review estate tax plans. Now is a particularly good time for business owners to think about estate tax planning. One such planning vehicle is a grantor trust—a way to…
Keeping Tax Papers
By Parag Patel, Esq. Keep anything related to your tax return for at least three years after you file. Keep anything related to your tax return, such as W-2 and…
New Tax Legislation Introduced: H.R. Bill 436 has Potential Changes to Estate and Gift Taxes and Available Discounts
…non-actively traded entity ownership interests between family members – Preserve the federal estate tax exemption equivalent at $3,500,000 – Set the marginal tax rate for estates exceeding the exemption at…
Tax-free Disaster Relief Payment Program
…tax law: Section 139 of the Internal Revenue Code. Section 139 allows employers to assist employees during a federally declared disaster with “qualified disaster relief payments” that are tax-free to…
15 IRS Audit Tips
…adjustments in these years too. 7. The IRS must complete an audit within three years of the time the tax return is filed, unless the IRS finds tax fraud or…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
…imposed and consented to under advice of counsel in the OVDP. When a taxpayer opts out, the IRS agent assigned will typically conduct an in depth interview with the taxpayer…
An Ill-advised IRS Streamlined Filing Compliance Procedure Filing
…is extremely important that a taxpayer’s eligibility is carefully analyzed because once the SFCP is elected and the taxpayer claims the violations were non-willful. There are possible risk factors that…
Form 3520 Penalty Relief
…the timely filing of their 2019 and 2020 tax returns. Because of the scale of the problem, the National Taxpayer Advocate, Members of Congress, and tax practitioner groups called upon…
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
…Filing Compliance Procedures (for non-willful taxpayers). Hence, taxpayers with offshore accounts who did not commit any tax or tax-related crimes and do not need the voluntary disclosure practice to seek…
Estate-Planning Preserves Medical Practice Value
…Living Trust also gave the surviving spouse the maximum marital deduction for estate-tax purposes. Ordinarily, an estate valued at over $600,000 will be subject to a federal estate tax, but…
Time Running Out for HSBC India accountholders sought by IRS
…earned by U.S. taxpayers on their HSBC India account. While India is not considered a tax haven or a financial secrecy jurisdiction, the information obtained by the IRS as stated…
The Tax Heat is On
…is a critical question of fact and law, based largely on the taxpayer’s particular facts and circumstances. Taxpayers with foreign accounts would be wise to retain experienced tax legal counsel,…
Recent Webcast to DC Bar Association on Post-Election Estate Planning and Audits: Tax Considerations For the Unexpected
…was hosted by D.C. Bar Estates, Trusts and Probate Law, D.C. Bar Taxation, D.C. Bar International Law Communities. Selected portions from the webcast can be downloaded below: Post Election: Tax…
Demystifying IRS Agents
…taxpayers. In my decades of experience as a tax attorney defending taxpayers on complex tax examinations (e.g., audits), I found IRS Agents to be normal people just like you and…
IRA Beneficiary Designation Planning
…IRA beneficiary must have precise terms in order to take advantage of the IRA’s tax deferral. With the wrong trust terms, the IRA balance must be distributed and taxed on…
Estate Tax Pitfalls Seen In Court Case
…outside of wills through vehicles such as life insurance, leaving less in the estate to cover tax obligations and complicating the issue of who owes how much in taxes. Non-probate…
Key Issues in Business Tax Planning in New Jersey
…business taxes – including all the latest updates. Purchase these reference materials and get helpful insight and recent updates on New Jersey’s business taxes. Find out how you can prosper…
What is a Stretch IRA?
…entire amount, creating a huge income tax. Naming a Stretch IRA Trust as the beneficiary of your IRA will ensure that your loved ones defer the built in tax for…