Search Results for: international tax
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…
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…
THE ABCs OF STRETCH IRAs
…“stretch” their Individual Retirement Accounts over generations, so that their heirs can receive IRA assets accumulated after decades of tax-deferred or tax-free growth. A stretch IRA can potentially create a…
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…
A Lesson From Brown v. U.S.: A Defective Tax Refund Filing
…with the IRS in order to receive their tax refunds. Facts of the Case U.S. Citizens, the Browns, in relevant tax years lived in Australia where Mr. Brown was employed….
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
…banks provide information on potential non-compliance by U.S. taxpayers. Potential civil penalties increase substantially if U.S. taxpayers associated with participating banks wait to apply to OVDP to resolve their 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…
FATCA Repeal Fails
…the IRS about their U.S. customers’ accounts. The U.S. loses an estimated $150 billion in tax revenue each year to tax haven abuse – a revenue shortfall that honest taxpayers…
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
…each and every tax return and informational return being submitted under the streamlined procedures. As the next step in the streamlined procedures, the taxpayer must submit payment of all tax…
Estate Planning for Non-US citizens
Estate Planning for Non-US citizens By Parag Patel Esq. Non-US citizens (greencard holders or H-1 visaholders) are severely discriminated against by US estate tax laws. Since estate taxes are based…
Comments on IRS Form 3520 to Report Foreign Gifts
…to the first tax year in question, but all tax years filed by the taxpayer during an initial reporting period. For example, if a taxpayer was not aware of the…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…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,…
Pandora’s Box Has Opened: Pandora Papers
…is legal, as long as the owner declares it to the tax authorities in the country where they reside. These companies benefit from low taxation, anonymity and the absence of…
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…Certain Foreign Gifts), although filed separately from the filer’s tax return, is due at the same time as the filer’s tax return, including extensions. Taxpayers and filers should be aware…
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
…can receive amnesty from criminal prosecution for their previously unreported offshore bank accounts in exchange for filing amended tax returns and FBARs, and paying all back taxes, interest, and penalties….
Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws
With the IRS aggressively targeting taxpayers with unreported offshore accounts, tax professionals must know benefits and pitfalls of offshore accounts. Our firm presented technical seminars titled Navigating Foreign Waters: The…
Problems with Joint Tenancy Property
…taxable. Estate tax penalty: A “credit shelter” or “bypass” trust is often used to reduce or eliminate estate taxes for the children or other beneficiaries of a married couple with…
Understanding the IRS Emphasis on BSA Filings in Tax Crime Investigations
…investigative priorities and how BSA reporting shapes its approach to tax-related crimes. Taxpayers impacted by BSA filings, including suspicious activity reports (SARs) and currency transaction reports (CTRs), show be concerned….
Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants
…Description: Hot Topics in Tax Controversy With new funding, the IRS has ramped up enforcement, and all tax professionals must be familiar with the latest strategies in audit and tax…
Beware Expected Employee Retention Credit (ERC) Audits
…taxpayer makes an unintentional mistake on their tax return. Interest is charged on any amount of tax that is owed to the IRS. If a taxpayer is found to have…
NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs
…to utilize the resources at our disposal to uncover U.S. taxpayers who willfully evade taxes by hiding their money out of the country.” We expect more prosecutions of individuals failing…
Which is better: an Incentive Stock Option (aka a statutory stock option) (an “ISO”) or a Nonqualified Stock Option (aka a Nonstatutory Stock Option) (an “NQO”)?
…at grant. Option taxable upon exercise? Not for ordinary income tax purposes; but spread is taxable for alternative minimum tax purposes (“AMT”). Exercise NOT subject to employment tax withholding. Yes…
Small PFIC Exception to Filing Form 8621
…that shareholder is required to file Form 8621. The PFIC shareholder must attach Form 8621 to its federal income tax return (or information return) each tax year, unless an exception…
Beware of FATCA Letters
…should immediately consult a US tax attorney about filing a foreign bank account report or FBAR (Fincen 114) and Form 8938. The IRS requires these from any US taxpayer with…
The New IRS ERC Voluntary Disclosure Program
…Upload Tool. Form 15434 must be filled out under penalties of perjury and include the following: Taxpayers’ names, taxpayer identification numbers, current addresses, and contact information. Tax periods for ERC…
Buy-Sell Agreements
…the owner of a small business can involve complex tax and non-tax issues when developing a buy-sell agreement among shareholders. From the standpoint of the corporation and the remaining shareholders,…
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…
Another Swiss Bank Discloses Customer Names to the US
…sends a clear message to anyone thinking about keeping money offshore in order to evade tax laws,” said Chief Richard Weber of IRS-Criminal Investigation (CI). “Fighting offshore tax evasion continues…
Foreign Account Tax Compliance Act – Traps for the Unwary
…even though such an asset is not currently taxable and any gain on the sale of the asset may not be taxable. The same would be true of tax-exempt assets….
Owner of Iberia Restaurants in Newark Found Guilty of Tax Crimes
…government criminally prosecutes more willfull taxpayers. A New Jersey man recently admitted failing to withhold and pay over payroll taxes stemming from his ownership of two well-known Newark restaurants. Jorge…