Search Results for: non-willful
New Webinar: An Introduction to the Taxation of Passive Foreign Investment Companies
…emphasis on investments in foreign mutual funds and foreign hedge funds Important elections to consider when making investments in PFICs Practical solutions to address non-compliance or missed elections in this…
Sale of Real Property from an Estate
…tax imposed on the transfer of property made upon the death of a New Jersey resident and certain non-residents, or made by such a decedent in contemplation of death. N.J.S.A….
GRATS: A Great Estate Planning Tool
…many non-tax benefits to GRATs. A GRAT can help you ensure succession. For example, if you want specific assets, such as stock in a closely held corporation, other business interest,…
New Jersey Tax Amnesty program
…and any delinquent tax returns, as well as make payments. If you didn’t receive a letter and you want to participate, you’ll need to register or self-report through the Non-Outreach…
Comments on IRS Form 3520 to Report Foreign Gifts
…a large foreign gift or inheritance received. It is confusing and nonsensical to keep disparate reporting in the same form. The second comment encourages the IRS to publicize that the…
IRS Guidance Targets Cash Reporting in the Cannabis Industry
…Non-Compliance Failure to correctly file Form 8300 can lead to substantial penalties, especially if the IRS determines the noncompliance was intentional. Historically, the IRS has prioritized compliance over using penalties…
How to Benefit from Tax Treaties
…means they apply to both countries. A non-resident of the US would be able to apply the same treaty provision to US income that a US resident could apply to…
AICPA Makes Useful Recommendations For International Forms 3520/3520
…Form 3520; Part III – for Line 29 – “If you are filing Form 3520 with respect to a foreign nongrantor trust, check N/A,” and for Line 30 – “If…
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
…in 2012, which followed voluntary programs offered in 2011 and 2009. The programs have enabled U.S. taxpayers to voluntarily resolve past non-compliance related to unreported foreign financial assets and failure…
New voluntary disclosure program for offshore accounts in 2011
…Act (“FATCA”) ensures that more information about foreign accounts will become available to U.S. enforcement authorities. FATCA will make it much more likely that any foreign financial institution, and non-financial…
FBAR statute of limitations court case ruling
…statutes, the Tax Court ultimately determined that the statute being used to assess additional income taxes from non-compliant taxpayers with foreign accounts could not be used for tax years prior…
Maryland Retail Store Owner Guilty of Tax Fraud and Tax Evasion
…a non-taxable gift rather than compensation related to Chawla’s employment in an effort to lower Chawla’s taxable income in any given year. Further, Saurabh failed to file a Form 1099…
FBARs from Wuhan
…unexpected future complications. All advisors should routinely ask about clients’ foreign accounts. There are various voluntary disclosure programs to correct past non-filings and noncompliance issues to affirmatively address such problems….
New Trust Law Enacted in New Jersey
…of a trust’s principal place of administration. Enables the non-judicial settlement of trust accounts and other matters related to trust administration; provided, such action is not contrary to a material…
IRS Letters and Notices Offering an Appeal Opportunity
…Non-filer Letter This letter advises you the IRS believes you are liable for filing tax returns for the periods identified in the letter. It includes a report giving you a…
Are You Ready For New FATCA Enforcement in 2020?
…in high penalties, account freezes, and criminal prosecution. If US persons are non-compliant with their foreign asset and income tax form reporting requirements, they should consider getting qualified tax legal…
US Entities with foreign assets have more information reporting
…instructions have been available since 2012 for use by non-resident US persons, but agreement had, at that stage, not been reached on exactly what types of ‘domestic entity’ would also…
IRS Announces New international campaigns
…1120F Chapter 3 and Chapter 4 Withholding Campaign and Verification of Form 1042-S Claimed on Form 1040NR Campaign are designed to verify withholding for refunds claimed by non-resident taxpayers. In…
IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable
International tax reporting requirements are complex, and the penalties for non-compliance can be severe. In Mukhi v. Commissioner of Internal Revenue, the U.S. Tax Court considered a case involving a…
NJ Tax Waiver Shortcut
…L-8 may be used to secure the Waiver or a From L-9 (or Form L-9NR for a non-resident decedent) may be filed to release New Jersey’s lien on real property….
Letter to Your Spouse
By Parag Patel, Esq. In addition to your estate planning, it’s a good idea to have a non-binding letter to your spouse, children and other heirs outlining where the important…
Powerful Post-death Planning Strategies for Trusts and Estates
…trigger an additional return filing requirement (by putting the remaining cash in a non–interest-bearing account, for example). 6. Set Aside Income From Charitable Assets If a decedent’s estate will ultimately…
Client Case Study: Tax Savings Now
…the gift, and the reduction to the estate tax exemption. In fact, with proper planning, both spouses could establish non-reciprocal SLATs for each other thereby potentially doubling the tax savings….
2009 Year-End Estate Planning News
…will be able to gift $26,000 to each donee. The amount of the Annual Gift Tax Exclusion with respect to gifts made to non-citizen spouses will increase from $133,000 to…
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
…required by FATCA about consenting U.S. accounts directly to the IRS. This requirement is supplemented by government-to-government exchange of information regarding certain pre-existing non-consenting accounts on request. Malta, the Netherlands,…
Checklist for for granting stock options
…provide the prospectus required by Rule 701. Eligible recipients- Confirm each prospective option recipient is eligible under the plan. Generally, only individuals qualify. Non-employee/consultants can qualify as long as they…
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)…
“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI
…the OVDI, but feel that their failure to file the FBAR form on an annual basis was “non-will”, may considering opting out. Who makes the determination as to willfulness and…
Make Sure You have Filed FATCA Compliance Certifications
…system to validate information collected. Account holders must provide a self-certification of compliance under FATCA. Failure to provide self-certification of compliance could result in the noncompliant accounts being blocked and…
Action Required: New Jersey Estate Tax is Repealed
…other than a Class A beneficiary (e.g., sibling, niece or nephew). Further, unlike the Estate Tax, the New Jersey Inheritance Tax applies to non-residents who own real estate or tangible…