Search Results for: streamlined filing compliance procedures
Should my business pay more wages or have qualified property to have a full 20% of profits Section 199A deduction, if you are a high earner taxpayer?
…Individuals who earn more than $210,700, and married couples filing jointly who earn more than $421,400 in 2019, will not be able to take Section 199A deductions on trade or…
“Financial interest” or “Signature Authority” in a Foreign Account
…or interest in profits,” other than a corporation, partnership, or trust. How We Can Help with FBAR Reporting If you have questions about the filing requirements and potential tax implications…
From Hong Kong With Love…
…temporarily with an intent to return or repay the funds later should not require a Form 3520 filing. W strongly recommend US tax legal counsel to guide US persons with…
What HSBC India Accountholders Can Expect From the IRS
…preliminarily cleared (the first stage of the OVDI process) to enter OVDI will not be removed from the OVDI program (even prior to the final filing of the taxpayer’s OVDI…
US Department of Justice Encourages Swiss banks to Disclose Information
…Fla., was convicted by a jury in Fort Myers, Fla., of conspiring to defraud the IRS and of filing false individual income tax returns. According to evidence presented at trial,…
How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes
…can request these by sending Form 4506 to the IRS. Filing Form 4506 confirms whether the decedent filed returns and demonstrates the executor’s good faith in determining the extent of…
Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)
…to a special six-year statute of limitations rather than the three years that usually applies to payroll taxes. Apply by filing Form 8952 at least 60 days before you want…
Another Customer with Unreported Offshore Bank Accounts Pleads Guilty
…submission (or maybe SDOP filing) may have saved Mr. Landegger. The case is interesting because it reveals the discussions between the bankers and client, which ultimately were criminally used against…
Caution: Increased FBAR Enforcement
…FBAR filing requirement and the government’s vigilant enforcement. The IRS has in its arsenal many ways to find out about Americans’ bank and or investment accounts they may have, how…
Our Best Net Investment Income Tax (NIIT) Tax Minimization Planning Strategies
…that exceeds $250,000 for MFJ (married filing jointly) or $200,000 (single). The NIIT generally applies to unearned passive income, not from a business. NII includes income from interest, capital gains,…
Silent Disclosure: The Qualified Amended Return (QAR)
…cannot sleep because the stance they took on their tax return was too aggressive). Filing a QAR in these situations may allow a taxpayer to avoid penalties stemming from the…
Estate Planning in New Jersey
…basis should you or your spouse be unable to do so. Probate “Probate” is the public process of: Filing and validating a will in court Paying all the debts and…
No tax = No Passport?
…some offshore banks are beginning to advise U.S. account holders of their obligations to report the accounts by filing FBARs and report income earned on the foreign accounts for income…
NJ Inheritance Tax
…Rest of the beneficiaries are taxed at 15 percent for the first $700,000 and 16 percent for estate amounting to more than that. Filing and Payment of New Jersey Inheritance…
The legal standard of “willfulness”: Opt out to avoid high penalties
…the Taxpayer was a grantor of, or transferor to a foreign trust (which requires filing Form 3520). A willful failure to file a FBAR can lead to a felony…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
…that our client will testify as to lack of any knowledge (also no evidence exists evincing such knowledge) that a FBAR filing requirement existed. Therefore, the Taxpayer could not have…
To Opt Out or Not Opt Out: That is the Question
…the case of Boston venture capitalist Michael Schiavo. Some possible criminal charges include tax evasion and filing a false return. Willfully failing to file an FBAR is also a violation…
The Unknown Tax: New Jersey Inheritance Tax
…her employer, that are considered qualified plans under the Internal Revenue Code. Filing and Payment of Tax Many times when all of a decedent’s property passes to the beneficiaries who…
Tax treaty tie-breakers
…result. It is important to note that tax treaty benefits do not provide an exemption from filing of most information returns such as IRS Form 8938 or FBARs. To take…
The New Jersey Civil Union Act: Tax Benefits?
…at the state level, they still must do so at the federal level. In general, federal income tax rates are higher than state taxes and filing jointly provides many exemptions…
Taxation of Employment-related Discrimination Claims
…and employees should be careful about the characterization of settlement amounts and be diligent in filing information with the IRS and state. A tax attorney can assist the parties in…
FBARs from Wuhan
…unexpected future complications. All advisors should routinely ask about clients’ foreign accounts. There are various voluntary disclosure programs to correct past non-filings and noncompliance issues to affirmatively address such problems….
IRS Listens, and Postpones Increased Form 1099 Reporting for PayPal and Venmo
As a result of taxpayer confusion, lack of guidance, concerns about the existing backlog, and impact on the upcoming filing season, tax professionals urged the IRS to postpone the implementation…
Another HSBC Customer Likely Going to Jail
…a Milwaukee neurosurgeon, Arvind Ahuja, of filing a false tax return and failing to file a Report of Foreign Bank and Financial Accounts, or FBAR, related to HSBC accounts in…
Important Provisions of the American Taxpayer Relief Act of 2012
…Ordinary Income. The new law increased the highest marginal federal income tax rate to 39.6% for married couples filing jointly with $450,000 of taxable income, heads of household filers with…
New IRS Forms Informs Beneficiaries of Asset Basis Values
…form. By law such submissions must be made available to the public. Penalties Executors who intentionally disregard filing requirements or fail to file correct Forms 8971 or furnish correct Schedules…
Visited by IRS Special Agents?
…time will elapse from the date an investigation starts until the filing of an criminal Indictment. In most instances, the target of a criminal investigation will be notified soon after…
What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 3520
…they do not need to do anything. A taxpayer may also dispute the penalty by first paying the penalty and then filing a claim at a later date. If the…
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
…or multiple accounts could lead to complications. In such cases, there are several voluntary disclosure programs to cure late or non-filing of FBARs., which should be seriously considered and explored….
New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back
…and prosecute advisors in other contexts. ERCVDP submissions are submitted through an online document upload, which is entirely different from past IRS voluntary disclosure programs that required paper filing. This…