What is a SLAT?
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
New Form 3520 Penalties
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
Malta pension plans listed on “Dirty Dozen” list of “tax scams”
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
Money Laundering 101
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
Consequences of Filing False Streamlined Filings
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
Implications of United States v. Horowitz: Reckless = Willful?
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
The IRS’ Complex Statute of Limitations
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
Willful FBAR Penalties
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
What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 3520
When receiving a penalty for failure to timely file Form 3520, Notice CP 15 or CP 215 is sent to the taxpayer notifying the taxpayer which requires a timely response. When receiving Notice CP 15
Penalties for Not Filing Form 3520
The IRS requires a U.S. person receiving a gift from a foreign individual, corporation, partnership, or estate to report by filing Part IV Form 3520. Failure to file or late, incorrect, or incomplete filing is
Expect new aggressive IRS targeted enforcement next year.
For years, the government has known about the widening tax gap, which reports uncollected taxes among US taxpayers. However, typically, the government does not do much to address the increasing loss of tax revenue. It
The big question on a tax increases is not “if” but “when”
We expect taxes to increase. The big question however is when the increase(s) will take effect. Although it is politically unpopular and unfair to change tax laws after people rely on them in making transactions