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Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

16 May, 2015

Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false tax returns. United States citizens

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Helpful Non-willful FBAR penalty case decided by court

6 May, 2015

For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty

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Checklist for for granting stock options

22 April, 2015

Every startup grants stock options sooner or later. Below is checklist for private corporations (not LLCs) granting stock options. Prior to Granting Stock Options Adopt a stock option plan – First, adopt a plan and

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A solution in a tough tax season: the IRS Streamlined Offshore Procedures

13 April, 2015

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

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Beware: India to sign FATCA agreement with US for sharing of information

9 April, 2015

Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian

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FATCA Repeal Fails

3 April, 2015

Last month US Senator Roger Wicker (R-Miss.) introduced a budget amendment SA 621 to repeal the Foreign Account Tax Compliance Act (FATCA)  FATCA requires foreign financial institutions to disclose to the IRS about their U.S.

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Another Swiss Bank Discloses Customer Names to the US

31 March, 2015

The Department of Justice announced today that BSI SA, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program.  Swiss private

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Which is better: an Incentive Stock Option (aka a statutory stock option) (an “ISO”) or a Nonqualified Stock Option (aka a Nonstatutory Stock Option) (an “NQO”)?

22 March, 2015

Many of our clients often ask: Which is better: an Incentive Stock Option (aka a statutory stock option) (an “ISO”) or a Nonqualified Stock Option (aka a Nonstatutory Stock Option) (an “NQO”)?  What are the

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Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

2 March, 2015

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 Complex Requirements of Foreign Accounts Compliance on US tax laws

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New Warnings in the IRS’ Streamlined Filing Compliance Procedures

31 January, 2015

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures.  The streamlined program was significantly expanded by the IRS

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Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

31 January, 2015

IR-2015-09, Jan. 28, 2015 WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty

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Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations

28 January, 2015

Internal Revenue Code (I.R.C.) Section (§) 6038(a) and Treasury Regulation § 1.6038-2(a) require a U.S. citizen or resident alien to furnish information with respect to certain foreign business entities. This information includes any foreign partnership/corporation

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