Search Results for: international tax
Year End Estate Planning Tips – Make Annual Exclusion Gifts
…tax exclusion. What is the purpose of these “estate planning” gifts? To reduce the value of the gift giver’s taxable estate. This year the annual gift tax exclusion is $13,000…
Canceled Debt: Taxable or Not
…lender forgives a taxpayer’s debt, generally, that forgiveness creates taxable “cancellation of debt” (COD) income under Section 61(a)(11). You must report any taxable amount of a canceled debt as ordinary…
Another U.S. taxpayer with an offshore HSBC bank account pleads guilty
…tax returns, false amended tax returns, and false FBARs. According to court documents, Ms. Bhasin of Huntington, NY, filed a false individual income tax return for 2008 that failed to…
Abatement of the NJ Amnesty Non-Participation Penalty is Still Possible for Some Taxpayers
…Services Co. v. Director, Div. of Taxation, 25 N.J. Tax 1 (Tax 2009)) which involved a taxpayer that was issued an assessment after amnesty had already closed. In UPS, the…
Comparison of Form 8938 and FBAR Requirements
…the tax year or $75,000 at any time during the tax year (higher threshold amounts apply to married individuals filing jointly and individuals living abroad) $10,000 at any time during…
Malta Pension Plan Being Investigated by IRS Criminal Investigation Division
The Malta Pension Plan is a tax-favorable pension plan that has been used by U.S. taxpayers in Malta. The plan allows for significant tax savings, as gains on assets contributed…
IRS Extends Late Portability Election Automatic Relief from 2 to 5 Years
…Proc. 2017-34, which allowed an estate that wasn’t required to file an estate tax return (due to the value of the gross estate and adjusted taxable gifts being under the…
IRS Enforcement Campaign Targets High-Income Non-Filers
…a new enforcement campaign targeting high-income taxpayers who have failed to file federal income tax returns. This campaign focuses on individuals with unreported income exceeding $400,000 annually for tax years…
IRS expands use of Subpeonas
…FATCA initiative, which forces financial institutions worldwide to report U.S. taxpayer accounts and assets to the SEC, U.S. tax authorities will get an even clearer picture of the offshore world….
Post-Covid: Re-explore the Home Office deduction
…home to deduct certain expenses on their tax return. In light of exponentially more taxpayers working from home almost exclusively due to the Covid pandemic, tax advisors should re-explore this…
Start or review an “Accountable Plan”
…tax return. Given the changes, it is a good time for advisors to establish their clients’ Accountable Plans. A good Accountable Plan creates tax savings both for you and your…
Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report
…to taxpayers’ annual income tax returns. The failure to timely provide this information results in a $10,000 penalty, even if this information does not affect taxpayers’ ultimate tax liabilities. The…
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
…penalty when a taxpayer files an untimely, but accurate FBAR, no matter how many accounts the taxpayer should have originally reported. United States taxpayers who have a direct or indirect…
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
…action for taxpayers who have become compliant. “Soft” notices from the IRS outlining taxpayer’s options, and requiring taxpayer response in cases of immaterial noncompliance. This letter will be sent by…
Should I close my foreign account?
…now? If you didn’t disclose the account on your tax returns and owe tax from the past, you face a tough choice. Staying hidden forever seems unlikely and is highly…
How to S T R E T C H Your IRA
The stretch IRA concept is a wealth-transfer strategy that can help you extend the period of tax-deferred earnings on your retirement assets. After the owner of the IRA dies, the…
Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency
…an undeclared overseas account at a foreign bank and has received a letter from their foreign bank they should retain a qualified tax attorney and come into tax compliance immediately….
Estate Planning for Families with Special Needs Children
…when the family is concerned with: income tax considerations; and if more than a million dollars will be going into the trust, possible federal estate and gift taxes. Tax planning…
The IRS can revoke your passport
…taxpayer representatives, even if they have a valid power of attorney on file that includes all of the tax years that comprise the seriously delinquent tax debt. The Taxpayer Advocate…
Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)
…of the community spouse. The community spouse-occupied principal residence is an exempt asset. N.J.A.C. 10:71-4.4. Consequently, prepayment of real estate taxes constitutes a valid spend-down. Begley, T. and Jeffreys, J.,…
Estate Planning and Life Insurance Trusts
…own a life insurance policy with a substantial death benefit. This is because life insurance proceeds, while not subject to federal income tax, are considered part of your taxable estate…
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
…that the taxpayer was non-willful between 2010-2011 because there was no clear evidence that the taxpayer had looked over any Schedule B when submitting the tax return. This means that…
Estate Planning New Year’s Resolutions
…tax upon your death. However, if you use an irrevocable trust to purchase your life insurance policy, it will be shielded from both estate and income taxes. If you have…
US real property now more attractive for certain foreign investors
On 18 December President Obama enacted the Protecting Americans from Tax Hikes (PATH) Act of 2015, extending several temporary tax relief provisions either permanently or for two or five years….
IRS Audits of Millionaires Remain Very Low
…tax returns and wealthy tax evaders and a legislative push for increased funding for the agency, the likelihood of a millionaire being audited in 2022 was just 1.1%. Instead, data…
Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation
…crackdown on offshore tax evasion since 2008, the U.S. Justice Department has charged dozens of U.S. taxpayers as well as more than two dozen offshore bankers, lawyers and advisers. Ahuja…
IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program
…compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed to allow U.S. taxpayers with offshore assets to become tax…
Are You Ready For New FATCA Enforcement in 2020?
…in high penalties, account freezes, and criminal prosecution. If US persons are non-compliant with their foreign asset and income tax form reporting requirements, they should consider getting qualified tax legal…
National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs
National Taxpayer Advocate Nina E. Olson today released her 2014 annual report to Congress, which expresses concern that taxpayers this year are likely to receive the worst levels of taxpayer…
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
…compliance procedures are designed for only individual taxpayers, including estates of individual taxpayers. The streamlined procedures are available to both U.S. individual taxpayers residing outside the United States and U.S….