Search Results for: offshore bank accounts
President-elect Obama’s tax plan
…start-ups and small businesses to encourage innovation. RETIREMENT ACCOUNTS Suspend mandatory distributions for those 70½ and older. Permit taxpayers to withdraw up to $10,000 from retirement accounts penalty-free; withdrawals would…
Tax Planning Opportunities for High Net Worth Individuals
…■ Individuals may consider naming tax exempt charitable organizations as beneficiaries of their qualified accounts and IRAs, the balances of which would be includible in an individual’s taxable estate and…
FATCA-Compliant Institutions List Goes Online
…nations, the requirements are beginning to take effect this year. FATCA requires foreign banks to reveal American accounts holding over $50,000. Non-compliant institutions could be frozen out of U.S. markets…
2008 New Year’s Resolutions: Keep your estate planning on the right track
…beneficiary designations for life insurance, retirement accounts and other assets to ensure that they are coordinated with your will or trust provisions. 3) Durable Power of Attorney Prepare (or have…
Probate of Estates in New Jersey
…the will). Estate administration encompasses all assets of the decedent – real estate, joint accounts, insurance, IRA’, etc. – anything and everything a decedent had any interest in when they…
IRS Clarifies Requirements for Streamlined Filing Procedures
…Our firm recently presented a informational webinar on the Streamlined Filing Compliance Procedures and the Offshore Voluntary Disclosure Program. Materials from the webinar can be downloaded here: Game Changer Streamline….
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
…We expect increased audit activity for clients with noncompliant Forms 5471 and foreign business activities. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset and income…
The IRS is Hiring: Expect New Enforcement
…fact that the Commissioner specifically mentioned illegal tax shelters and international tax compliance may indicate that taxpayers with offshore assets may soon be at an even higher risk of the…
The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers
…the old Offshore Voluntary Disclosure Program (OVDP), taxpayers do not receive automatic protection against criminal/civil penalties and the IRS has wide discretion to impose penalties based on the taxpayer’s level…
New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471
…tax advisers with the tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide…
New York State Bar Association Proposes OVDI Changes to IRS
…offshore, there is an obvious reason to come in now. If we find you, you face harsher penalties and the possibility of jail time. If you come in voluntarily, you…
IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application
…Criminal Investigation Voluntary Disclosure Practice IRM 9.5.11, Investigative Process – Other Investigations IRM 4.63.3, Withholding and International Individual Compliance – Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary…
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
…examination or a request for delinquent returns.” The above FAQ 18 assurances are not contained under the New Procedures for Delinquent Offshore International Returns. It is now more important than…
IRS Announces Increased Enforcement on Form 5471
…offshore dealings and on curtailing noncompliance. The campaign does not address whether filing an amended return with the Form 5471 appropriately attached will enable taxpayers to mitigate consequences that might…
How to Avoid Criminal Prosecution Through Voluntary Disclosure
…seek protection from potential criminal prosecution. Through this program, a Taxpayer can limit their offshore non-compliance and thus limit their penalties to six years. The first step in Voluntary Disclosure…
Welcomed Tax Relief to U.S. Individuals Owning Stock in “Controlled Foreign Corporation”
…was introduced by the Tax Cuts and Jobs Act 2017 (TCJA) in order to encourage large multinational enterprises to repatriate profits stored offshore. The TCJA introduced a ‘participation exemption’ incentive…
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
The IRS revised its Delinquent International Information Return Submission Procedure (DIIRSP) last week. The DIIRSP provided an alternative 0% penalty voluntary disclosure process to taxpayers other than the Offshore Voluntary…
Estate Planning in a Recession
…investing, business start-up, education, home purchase, and other purposes. The IRS sets minimum interest rates for these types of loans, well below bank rates, depending on the maturity date. Lower…
Understanding the IRS Emphasis on BSA Filings in Tax Crime Investigations
The Internal Revenue Service (IRS) places significant emphasis on the role of Bank Secrecy Act (BSA) filings in supporting the work of its Criminal Investigations (CI) division. Their recent report…
Money Laundering 101
…funds to purchase foreign currency), blending funds (mixing illegal money and legitimate money together). After placing the money into the system, criminals begin moving the funds between different banks, financial…
IRS Enforcement Campaign Targets High-Income Non-Filers
…garnishment, bank levies, or federal tax liens. Willful non-filing carries the potential for criminal prosecution. Strategic Implications This campaign signals a shift in IRS priorities, highlighting its ability to pursue…
IRS Most Common Tax Notices and What They Mean
…IRS is proposing changes to your tax return based on information that they received from your employer, bank and/or other third party payers. This notice is generally referred to as…
Adding Beneficiaries to an Irrevocable Life Insurance Trust
…irrevocable trust is to make a gift into it. Therefore, the grantor will make a gift by way of writing a check into the ILIT bank account in the amount…
Resolving IRS disputes through audit reconsideration
…be corrected; Information that supports the taxpayer’s position, including necessary documents such as Forms 1099, canceled checks, bank statements, and loan documents; and Copies of letters and reports the IRS…
INHERITANCE TAXES IN NEW JERSEY RATES
…institution may release up to 50% of any bank account, certificate of deposit, etc. to the survivor, in the case of a joint account, the executor, administrator or other legal…
Estate-Planning Preserves Medical Practice Value
…do is list all of your assets. Write them down–the equity in your home, the amount of your bank account and the value of stocks, bonds, insurance policies, IRAs, jewelry…
FBAR Deadline Extended to December 31, 2021
The Financial Crimes Enforcement Network (FinCEN) today issued a notice extending the filing date of Reports of Foreign Bank and Financial Account (FBARs) for victims of recent natural disasters, including…
A Change in Domicile to Florida Can Help Minimize Taxes
…and close out a New York box. Open a Florida bank account. Change credit cards to the Florida address. Execute a new Florida will, Florida durable power of attorney, and…
Businesses Owners Need To Plan for Their Exit: Companies should be prepared for the boss’s departure
…won’t have an unexpected shareholder entering the business,” Patel says. “Without a plan, you can have a bank become a shareholder in the case of a bankruptcy,” he adds. “And…
Buy-Sell Agreements
…the ex-spouse from owning stock). 6. Bankruptcy. Establishing the Purchase Price Establishing the purchase price is one of the most critical provisions of the agreement. Too often, a valuation is…