Yesterday the IRS stated that taxpayers’ eligibility to participate in the OVDP could be terminated if the foreign institution where you have your account faces IRS action. Once the U.S. government has taken action against
The Internal Revenue Service appears to have finally created a process to finally separate small non-resident (foreign resident) US taxpayers from larger non-resident US taxpayers at the front end, and not force everyone through the
For years now wealthy people have used dynasty trusts to shield their assets from estate taxes for tens and hundreds of years, or even forever. But the dynasty trust is under attack from a new
In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business / Self-Employed Division is reported to have
Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have
Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other
Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S.
Comparison of Form 8938 and FBAR Requirements Many holders of foreign financial assets must file two disclosure forms this year or else risk draconian penalties. They are Form 8938, which is due with
This year, there is at least one new tax form for US taxpayers to be aware of: Form 8938: Statement of Foreign Financial Accounts. Since there are a number of sometimes obscure U.S. tax forms
The IRS has finally attempted to demystify its new Form 8938. Below are some Form 8938 FAQs: Basic Questions and Answers on Form 8938 1. What are the specified foreign financial assets
The 2010 Tax Act is scheduled to expire on Dec. 31, 2012, at which time under current law the opportunities afforded under the 2010 Act will be lost. This article explores various tax planning opportunities
