Search Results for: irs appeal
Rare Supreme Court Ruling Favors Taxpayers!
…cause). In the case, the IRS asserted that Bittner violated the law 272 times, once for each account not reported in those five years. Bittner said he violated the law…
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…
New Webinar: An Introduction to the Taxation of Passive Foreign Investment Companies
Event Details May 9, 2022 3:00 pm to 4:00 pm Many investors unknowingly invest in Passive Foreign Investment Companies (PFICs) and as a result must file IRS Form 8621, Information Return…
REPORTING FOREIGN ASSETS & ACTIVITIES: REQUIREMENTS AND CHALLENGES: Complimentary CPE Presentation
Join us for a Complimentary CPE Presentation on Reporting Foreign Assets & Activities: Requirements and Challenges Penalty structure Best practices in reporting IRS penalty avoidance programs Latest Supreme Court case impacting…
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…
Are Trusts Required to Report under the Corporate Transparency Act (CTA)?
…an entity created by filing a document with a state’s secretary of state. A trust often needs to file with the IRS to get an EIN, but that is a…
FBAR Deadline is June 28, 2013
…it to FinCEN (not the IRS) by June 30 of the following year on Form TD F 90-22.1. Note that this is not a tax filing, so FinCEN must receive…
The Tax Issues of Expatriation
…are a resident of the treaty country and notify the IRS of that treatment on Forms 8833 and 8854. See Effect of Tax Treaties in chapter 1 for more information…
What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?
…implications. A PFIC is a foreign corporation that meets certain criteria related to its income and asset composition. PFIC rules were established by the U.S. Internal Revenue Service (IRS) to…
New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP
…The IRS has also started to establish exclusive “optout” offices, which probably means that more optouts are expected. Regardless, while opting out of the OVDI or OVDP amnesty programs may…
The 65-Day Rule: What Every Trustee Should Know about Taxes
…the 65-Day Rule, the trustee must make the 663(b) election on page two of IRS Form 1041, the trust’s income tax return. If the trustee makes this election, he should…
Sale of Real Property from an Estate
…To discharge the lien, a Certificate of Release of Estate Tax Lien can be obtained from the IRS and recorded with the County Clerk in the county in which the…
Required Minimum Distributions Suspended For Retirement Plans and IRAs For 2020
…technical tax bill looking for revenue, so expect the IRS and the government to interpret the bill under that notion. The CARES Act also created a new exception to the…
Unfiled FBAR Penalties Survive Death
…FBARs were missed. If any FBARs are unfiled it would be wise to file them under one of the IRS’ voluntary/amnesty disclosure programs to correct errors and become compliant before…
Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?
…their shareholders. These amounts are then reported annually to the IRS on a Form 1099. Foreign investment companies are not subject to U.S. taxes or to these disclosure rules. As…
Happy Birthday Streamlined Filing Compliance Procedure!
The Streamlined Filing Compliance Procedure (SFCP) was “born” two years old. Two years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with…
Tax-free Disaster Relief Payment Program
…a disease pandemic. The IRS has not issued any guidance specific to COVID-19 and thus it is not entirely clear what types of expenses during this time will be considered…
Frequent Scenarios in Offshore Voluntary Disclosures
…returns (Report of Foreign Gift or Bequest) on a timely basis to avoid severe penalties. As the IRS focuses more and more resources on international tax evasion techniques and tax…
Estate Planning for Non-US citizens
…the IRS after the death of their spouse, the tax law denies any estate tax marital deduction for property passing to non-US citizen spouses. Thus, there are only three choices…
Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA
…the Trinidad and Tobago government which will, in turn, relay that information to the IRS. To bring the agreement into force, Trinidad and Tobago’s Parliament must now pass the necessary…
IRA Beneficiary Designation Planning
…never name the estate or other non-individual as a primary or contingent beneficiary. The only exceptions are when there is no interest in allowing heirs to use the tax deferral…
Parag Patel Esq. presents new tax law changes at Broward Chapter of The Florida Society of Enrolled Agents (FSEABC) Webinar
…Broward County. Members are licensed by the U.S. Department of the Treasury to represent taxpayers before all administrative levels of the Internal Revenue Service (IRS), including collection, audits and appeals….
No Clawbacks for Gifts if Estate Tax Exemption Changes
…last month the IRS issued Treasury Regulations to avoid the clawback. These new regulations allow estates to compute the federal estate tax using the higher of the exemption amount applied…
Deferral is the Name of the Game: Funding a Trust With Retirement Assets
…the surviving spouse’s attainment of the age of 70 ½. After that date, in most cases, the required minimum distributions are based on IRS tables which factor in the life…
An exception to PFICs in Foreign Pension Plan Accounts
…become US persons while owning such interests). Typically, foreign mutual funds are deemed PFICs, which lead to onerous tax reporting. The Treasury and IRS recently released regulations that provide guidance…
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial…
Discriminatory Taxation: Greencard and H-1 Estate Planning
…prevent the loss of tax revenue from a non-US citizen, who may decide to “take-the-money-and-run” back to a foreign country and beyond the reach of the IRS after the death…
FBAR Deadline Automatic Extension
…the date individual Federal income tax returns are due. A cording to IRS IR-2021-83 dated April 9, 2021:Filers missing the April 15 deadline will receive an automatic extension until October…
Checklist of tax forms for taxpayers with foreign assets
…used to calculate tax on your PFIC income. If you wait to file Form 8621 until you have realized gains or distributions, you’ll have to accept the IRS’s punitive default…
Stretching Your IRA to the Next Generation
…heirs. For those intending to bequeath their individual retirement account funds to survivors, a change in Internal Revenue Service regulations in January of 2001 (followed by an April 2002 revision)…