Search Results for: international tax
FATCA Deadlines Extended
Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued…
A great time for GRATs
Estate planners are constantly looking for ways to assist their clients with transferring wealth from senior generations to junior generations with little or no gift tax consequence. In addition to…
Taking Advantage of Low Interest Rates
…to avoid imputed interest for gift and income tax purposes. The 7520 rate is also calculated and published each month by the IRS and represents the interest rate used to…
From Hong Kong With Love…
…Received During the Current Tax Year from Foreign Persons”. Part IV of Form 3520 asks you to list certain gifts or bequests received during the tax year from foreign persons….
Why should you do estate planning in a down economy?
…taxes are alive and well. New Jersey exempts only $675,000 per decedent for the state estate tax. New York exempts only 1 million per decedent for its state estate tax….
Watch Out: Malta Pension Plans Become Listed Transaction
…the IRS will take the position that taxpayers are not entitled to the purported tax benefits. A tax attorney with experience in the Malta plans can assist taxpayers in compliance….
New US-Malta Agreement Targets Pension Planning by US Taxpayers
…IRS is actively examining taxpayers who have set up these arrangements and recognizes that other taxpayers may have filed tax returns claiming Treaty benefits as a result of their participation…
The questions most frequently asked about probate in New Jersey.
…account. Remember that existing accounts are allowed to be accessed up to one-half of their value pending the tax waivers being received. 18) How soon must state inheritance taxes be…
Questionable ERC could mean trouble for CPAs
…vetting an ERC calculation, the IRS has provided a list of “red flags” for taxpayers and tax practitioners to look out for, which include a third party being able to…
Parag Patel Esq. Speaks to New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group
…tax and compliance requirements that apply to tax-exempt, not-for-profit entities. The program covered new tax court decisions, recent IRS publications, the latest tax legislation that will impact tax-exempt entities, IRS…
Charitable Remainder Trust: Frequently Asked Questions
1. What is a Charitable Remainder Trust? A Charitable Remainder Trust is a special tax-exempt irrevocable trust arrangement written to comply with federal tax laws and regulations. You transfer cash…
BE-10 Report: A New Overlooked International Reporting Form
…The form is unrelated to taxes. It is part of the US Department of Commerce’s efforts to conduct surveys every five years of US direct involvement in foreign business enterprises….
IRS announces new Streamlined Filing Compliance Procedures
…$0 penalty as long as these failures resulted from non-willful conduct. SDOP description and submission instructions are available at http://www.irs.gov/Individuals/International-Taxpayers/U-S-Taxpayers-Residing-in-the-United-States. Persons residing in the United States applying for the new…
The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers
…the tax underpayment will apply to only the one tax year with the highest tax liability, but examiners may apply it to more than one year up to all six…
New IRS Voluntary Disclosure in 7 Steps
…OVDP program). CI will not process tax returns or tax payments. CI will notify the taxpayer by letter of preliminary acceptance of the voluntary disclosure submission. CI will forward the…
Republican Party Rallies Against FATCA: Success Unlikely
…continues to gain momentum and international support as we work with partners around the world to fight offshore tax evasion.” Our law firm believes that FATCA is here to stay….
Major changes to IRS offshore voluntary compliance programs
…report offshore accounts was not willful. Because taxpayers’ non-U.S. investments vary widely, the IRS offers the following options for addressing previous failures to comply with U.S. tax and information return…
New voluntary disclosure program for offshore accounts in 2011
…subject to IRS inquiries, does not mean that it will not be. President Obama has targeted taxpayers with foreign accounts as lost tax revenue. The new Foreign Account Tax Compliance…
IRS Announces Increased Enforcement on Form 5471
…Form 5471 by attaching it to a tax return. For taxpayers who failed to attach required Forms 5471 to their tax returns, this campaign cautions that amended returns should be…
The InSECURITY of the SECURE Act
…withdrawn free from federal income tax. So, under the pre-SECURE Act RMD rules, a stretch Roth IRA could provide protection from future federal income tax rate increases for many years….
Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts
According to a DOJ Tax Press Release, here, the IRS has arrested a U.S. Citizen and two Canadian citizens who offered enabler services to U.S. taxpayers. They were caught in…
New Jersey State Income Taxation of 2010 Conversion of a Traditional IRA to a Roth IRA
…the Federal Tax Increase Prevention and Reconciliation Act of 2005 provision regarding the Federal Income Tax reporting of a distribution from an IRA which the taxpayer converts into a Roth…
New Jersey Department of Revenue publishes “Manual of Audit Procedures”
…nexus, and various subjects related to specific tax types (e.g., sales and use tax and corporation business tax). The Division explains that it will update this manual periodically to reflect…
Family Limited Liability Companies (LLCs)
…Section 2038 “bona fide sale” exception applied, so that the transferred assets were not subject to estate tax. The Tax Court agreed, holding that the LLC’s activities do not have…
President Trump Revamps the IRS through his 2019 Taxpayer First Act
…be a genuinely independent appellate administrative office to listen to taxpayers present their cases to the IRS. The office will work to resolve tax issues (i.e., unagreed income tax audit…
Stretch your IRA
…IRAs. Individual Retirement Accounts (IRAs) have been one of the most popular retirement vehicles for the past generation of investors. They let you enjoy tax-deferred savings over an extended period…
New law complicates US Passport issuance
…be affected by the new law, but stay tuned. This is an unprecedented aggressive change in US tax collections law, which will likely scare many people into becoming tax compliant….
Is HSBC the next UBS nightmare?
…does not condone tax evasion and fully supports the U.S. efforts to promote appropriate payment of taxes by U.S. taxpayers.” Nonetheless, clients with a foreign HSBC account should be seriously…
New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back
…IRS had little advance or no information about questionable tax positions (i.e., unreported foreign accounts), the ERC is a domestic tax benefit involving electronically filed employment tax and income tax…
How to Limit a Executor’s Personal Liability for Taxes
An estate’s executor or adminstrator, also know as a personal representative (“PR”), is personally liable for paying the decedent’s remaining tax bills, be they income taxes, gift taxes or estate…