All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or signatory
In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. Although not
The Streamlined Filing Compliance Procedure (SFCP) was “born” six years ago. Six years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets.
While a slat is commonly known as a thin, narrow strip or bar of wood or metal, a SLAT is also known to estate planning professionals as a Spousal Lifetime Access Trust (SLAT). With the
In November 2020, the IRS changed the rules for assessing penalties for Form 3520, the Annual Return to Report Receipt of Foreign Gifts. Form 3520 is filed for any U.S. Taxpayer who receives a foreign
Last week, the Internal Revenue Service (IRS) placed certain Malta-based pension plan arrangements on its annual “Dirty Dozen” list of “tax scams.” In its recent news release, the IRS warns that it is evaluating the
Over the years, some clients and advisors have asked us about how to detect possible money laundering activities. To do so, an explanation of the basics is required. Money laundering is the process in which
The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced penalty. However, to be eligible
In a recent court case, a court found that “willfulness” in the context of civil FBAR penalties is satisfied by recklessness and does not require disregard of a known legal duty. In United States
An IRS tax audit can be expensive and stressful. That is why is always important to check whether the IRS statute of limitations has expired for the audit. The expiration of the statute of limitations
U.S. Citizens who have a financial interest in or signature authority over foreign bank accounts that hold an aggregate amount greater than $10,000 are required to report the accounts to the IRS each year by
