U.S. Tax Court: What to Expect
Reasons to Take Your Matter Before the United States Tax Court: You’ve recently undergone an audit or examination. You have taken the proper administrative steps to argue your case but still receive a notice of
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16
India issues FATCA Self-certifications and KYC Warnings
The Government of India continues to crackdown on self-certifications and know your customer (KYC) compliance for financial accountholders. Earlier this month the government said that the account holders of any financial institutions need to provide
IRS Issues Reminders for FBARs and other International Requirements
The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At the same time, the agency
How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes
Being an executor can often be a demanding and thankless task. In addition to coping with the loss of a close friend or family member, executors are routinely charged with navigating estate plans through an
Using the 65-day rule as an opportunity for income tax savings for estate
One of the tax planning tools available to executors of estates is the 663(b) election, also known as the “65-day rule.” Simply put, a 663(b) election allows distributions made to beneficiaries within 65 days of
New Jersey Department of Revenue publishes “Manual of Audit Procedures”
On March 7th, the New Jersey Department of Revenue released its “Manual of Audit Procedures” to the public, which is intended to provide a comprehensive overview of the procedures and guidelines available to it for
2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases
The US Dept of Justice (DOJ) Tax Division recently published it annual summary highlights of civil tax matters. The publication is linked here (Updated through December 16, 2016), and contains brief summaries DOJ Tax activity (decisions, court
Individuals with disabilities can create their own self-settled trusts
The Special Needs Trust Fairness Act provides that individuals with disabilities can now create their own special needs trusts instead of having to rely on others. The Act was included as Section 5007 of the 21st Century Cures
IRS Announces new OVDP Declines-Withdrawals Campaign
Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance. One of those areas involves the IRS Offshore Voluntary
Avoiding and Defining Willfulness
U.S. taxpayers with unreported foreign accounts or assets are in a challenging position. The IRS has repeatedly announced that it is devoting resources to finding and penalizing taxpayers who do not disclose such offshore accounts and assets.
Common Issues for US-India Tax Reporting
US-India Cooperation: In 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015.