Search Results for: irs appeal
Our Best Net Investment Income Tax (NIIT) Tax Minimization Planning Strategies
…minimize the tax: Sell securities with losses before year-end to offset gains during the year from the sale of securities. Donate appreciated securities instead of cash to IRS-approved charities so…
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “A New Foreign Frontier: Foreign Income & Asset Reporting Update”.
…Update ” on November 18, 2022. Seminar Summary: The IRS is aggressively targeting taxpayers with unreported foreign accounts and income. Tax professionals must identify the pitfalls of the new world…
Short Lived Planning Opportunities for the Rest of 2012
…The assets in these trusts, once the two spouses pass away, including the appreciation on the assets that were gifted, will avoid estate taxation. This is a very appealing planning…
Explore the OVDI opt-out option: Argue for Penalty Mitigation
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with six examples. See FAQ 51….
Rare confluence of tax law and immigration law
…on the interest and dividend income she earned in her Swiss bank account and failed to file tax returns with the IRS for tax years 2011-2014. The indictment also charges…
“Leave a Legacy” – Beneficiary Designation on your Retirement Plan
…your death, then use other assets to make a charitable gift. But there’s a tax trap in such an arrangement: The IRS considers the balance left in your retirement account…
A Change in Domicile to Florida Can Help Minimize Taxes
…more homes, the domicile is the one regarded and used as the permanent home. The leading case in New York was decided by the New York Court of Appeals in…
Family Limited Liability Companies (LLCs)
…Mirowski gifted a 16% interest in the LLC to each of the trusts. A mere four days later, she died unexpectedly. The IRS argued under Section 2036(a) of the Internal…
Willful FBAR Penalties
…the IRS each year by filing a Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers must file the FBAR annually and the last day to timely file is at…
Family Limited Partnerships, or more commonly now, Family Limited Liability Companies, are great vehicles for management & protection of family assets
…to stand up to IRS scrutiny, it is important the FLP or FLLC be properly formed and administered. See the below checklist to help determine if your family entity meets…
Estate Planning in New Jersey
…IRS Make gifts on your behalf Create and amend any trusts you set up You don’t need to transfer any assets at the time you sign a power of attorney,…
A Good Time To Review Estate Tax Plans: Decline in asset value prompts new strategies
…transfer business interests and other assets to next-generation heirs while minimizing estate tax liability. A low-interest-rate environment could open up good opportunities to move a business from the senior generation…
Caution: Foreign Businesses Require Additional Reporting
…that information to the IRS so that the U.S. partners’ tax liability can be determined. Enforcement of such onerous rules has significantly ratcheted up with the introduction of FATCA and…
The Secret Stretch IRA
It may seem like a contradiction, but there is a way to leave a lot of money to your heirs even if you’re not rich. Individual retirement accounts (IRAs) were…
Important Provisions of the American Taxpayer Relief Act of 2012
…will be adjusted annually for inflation (it is expected that the IRS will set it at $5,250,000 for 2013). The $5,000,000 indexed exemption for the generation skipping transfer tax has…
Citizenship renunciation fee increases as American expatriates flee FATCA
…in any case, the IRS will impose an exit tax in the form of a capital gains charge on assets declared. It is also legally impossible to renounce citizenship while…
HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose
…investigation. For persons with undisclosed foreign accounts, KYC procedures means the likelihood of discovery is all the greater. Once the IRS identifies an individual for investigation then the Offshore Voluntary…
Small PFIC Exception to Filing Form 8621
…PFIC shareholders are required to complete and file Form 8621 with the IRS. A foreign mutual fund is typically going to be considered a PFIC. The reason why is because…
Increase in the annual gift tax exclusion to $14,000
The IRS recently increased the annual gift tax exclusion from $13k to $14K in 2013. The annual gift tax exclusion is the amount you and your spouse can each gift…
Buy-Sell Agreements
…estate could be liable for taxes based on the IRS revaluation, where it has only received the value based on the formula in the agreement. This could result in an…
Non-Resident Estate Tax Trap
If you’re not a U.S. citizen or resident, you might think you have no U.S. tax obligations. But if you hold shares in any U.S. corporations, your heirs may face…