The Tax Issues of Expatriation
The “United States Permanent Resident Card”, also known as a Green Card, as a work and residence permit for the USA of unlimited duration and as an immigration visa, constitutes an admission ticket to the
IRS expands use of Subpeonas
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a
Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income
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
Helpful Non-willful FBAR penalty case decided by court
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
Checklist for for granting stock options
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
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
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
Beware: India to sign FATCA agreement with US for sharing of information
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
FATCA Repeal Fails
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.
Another Swiss Bank Discloses Customer Names to the US
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
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”)?
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
Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws
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
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
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