Search Results for: international tax
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
…of the federal information, the NJ tax liability, including tax, interest, the 5% late payment penalty and the 5% amnesty penalty, will be finalized. At such time, the taxpayer will…
Non-Resident Estate Tax Trap
…a huge tax bill when you die. The culprit is an obscure provision in the Tax Code. Section 2104 reads, in part: “Shares of stock owned and held by a…
Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks
…data regarding US taxpayers who hid their income and assets from the US and with a list of financial institutions and financial advisors who participated in the tax non-compliance of…
US Department of Justice Encourages Swiss banks to Disclose Information
Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters…
New IRS practice unit: “Substantial compliance” doctrine, international information return penalties
The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties,…
IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution
…Patel Law Offices at 732-623-9800 or visit us at http://www.PatelLawOffices.com. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems….
Opt Out of OVDI Program Penalties to Get a Lower Penalty
…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts….
OVDI: Requesting issuance of a FBAR warning letter instead of penalties
…civil audit examinations. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and…
Frequent Scenarios in Offshore Voluntary Disclosures
…more and more resources on international tax evasion techniques and tax evasion careful reporting is a must to avoid penalties, including penalties for tax evasion, tax fraud and FBAR penalties….
HSBC Expected to Disclose Account Holders Names
…immediately and consider entering the IRS’ new offshore amnesty program. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems….
HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS
…offshore amnesty program. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…clients regarding their offshore asset and income compliance issues. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our…
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
…recording a tax liability on the IRS’s records for a taxpayer. After assessment and failure to pay, the IRS can enforce the collection of tax, penalties and interest by asserting a lien…
Rare confluence of tax law and immigration law
A recent case highlights the rare confluence of tax law and immigration law. This week a federal grand jury indicted Lucia Andrea Gatta, with tax evasion and failing to file…
New Portability Election Extension Prevents Lost Estate Tax Exemption
…Portability Currently, each individual has a federal gift tax and estate tax exemption amount of $12,060,000 (in 2022). Any exemption amount not used for lifetime gifts remains available at death…
Do Inherited Foreign Assets Receive a Step-up in Cost Basis for U.S. Tax Purposes?
…related to cost-basis for inherited non-U.S. assets. What is a “step-up” in cost basis at death? Under current U.S. tax law, the income tax basis of inherited assets is updated…
Pointers on the Yearly Gift Tax Exemption
…the gift does not have to pay the tax The exemptions for gifts and the gift tax rates are established by the IRS. In 2009 the gift tax exemption threshold…
Welcomed Tax Relief to U.S. Individuals Owning Stock in “Controlled Foreign Corporation”
…taxable year of a US person in which or with which such taxable year ends. Taxpayers can also rely on it for the 2018 taxable year. This is good news….
NJ Tax Waiver Shortcut
New Jersey provides its taxpayers the opportunity to pay two “Death Taxes”: the New Jersey Inheritance Tax and the New Jersey Estate Transfer Tax. These taxes are transfer taxes (not…
Naming A Minor as Your IRA Beneficiary
…the trust’s income tax rate, and any amounts distributed to or for the benefit of the child would be taxed at his or her personal income-tax rate. An accumulation trust…
Becoming Un-American: Record number of US citizens renounce their US citizenship
…you live, and often pay US taxes on top of the tax you already pay in your country of residence – so-called double taxation. This has been the case in…
Estate Tax Marital Deduction: Don’t “Overqualify”
…gift taxes (“transfer” taxes). A husband and wife, therefore, should be able to transfer to their children (or other beneficiaries) a total of $1,300,000 in assets free of transfer taxes:…
Pre-Immigration Income Tax Planning
Since the United States has some of the highest tax rates and most complex tax rules in the world pre-immigration tax planning is very important (but rarely done). Various actions…
Protective Filing of Information Returns
…files a tax return with respect to a given taxable year, then there is no statute of limitations on the IRS’s right to assess additional taxes for that year. Regardless…
U.S. Tax Court: What to Expect
…statement of taxpayer ID and a designation of place of trial should be filed in conjunction with the petition. A taxpayer should also remember to pay the appropriate fee when…
New FBAR Deadline applies to 2016 Tax Year Onwards
…Tax Return filing deadlines, but it also means that taxpayers and tax-return preparers have additional work to do by those tax return filing deadlines and that the FBAR deadline for…
How Long is the Tax Fraud Statute of Limitations?
…of limitations does not run during that time. Unlike civil tax fraud, with criminal tax fraud, the government must prove the case beyond a reasonable doubt. Also unlike civil tax…
IRS’ New “Dirty Dozen” list of tax scams
…tool allows taxpayers to confirm eligibility and provides an estimated offer amount. Taxpayers can apply for an OIC without third-party representation; but the IRS reminds taxpayers that if they need…
Administrator of a Probate Estate: Duties and Responsibilities
…(both federal and state), the federal estate-tax return, the state death tax return (estate and inheritance), and the deceased’s final income tax return (federal and state). Taxes usually must be…
Received a FATCA Letter from Your Foreign Bank?
…are the potential consequences of FBAR non-compliance or other tax problems? If a US taxpayer has failed to comply with his or her FATCA, FBAR, or other income tax reporting…