Search Results for: non-willful
Should I aggregate different businesses for wage and qualified property calculation purposes, or consider them to be separate on to maximize my 20% Section 199A deduction?
…can also be aggregated, but residential rental property operations cannot be aggregated with non-residential rental operations under the new regulations. This is a complicated area of tax law. It is…
INHERITANCE TAXES IN NEW JERSEY RATES
…intangible personal property wherever situated, or A nonresident decedent for the transfer of real or tangible personal property located in New Jersey. No tax is imposed on nonresident decedents for…
India and the US have agreed to collaborate on offshore tax evasion
…deposit taking non-banking finance companies, mutual funds, private equity funds, custodians and life insurance companies, will have to maintain information about their customers, including name, address, tax identification number and…
HSBC and NRI Bank Accounts: Could It Spread to Other Banks?
…office in New York City to enable non-resident Indians (NRIs) living in the United States to open accounts in India,” it said. The US Justice Department said in 2007, HSBC…
For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language
In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published…
Financial Crimes Enforcement Network (FINCEN) Issue Final Rules
…per custodial arrangements, such as omnibus accounts, FinCEN clarified that in situations where the U.S. person can only access their non-U.S. based holdings through the U.S. custodian there is no…
New Tax Changes are Blowing in the Wind
…like insurance trusts. In addition, sales from grantor trusts to its owner would now be a taxable transaction. Changes to valuation methodologies, including limiting valuation discounts on transfers of non-business…
Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)
…to include non-U.S. persons “in and doing business in the United States.” However, for 2008 and 2009 FBARs (due in June 2009 and 2010, respectively), the IRS allowed taxpayers to…
Substantially Completed Form 5471 is Required to be Filed
…non-compliance: Stating that required information will be furnished upon request or audit; Providing computer-generated Form 5471s that were not IRS-approved and did not conform to requirements; Failing to provide financial…
US Reporting of Foreign Retirement Accounts
…purposes, or for the purchase of a primary residence. 6) If the trust is employer-maintained, then certain additional requirements must be met: a) the trust must be nondiscriminatory insofar as…
Foreign Account Tax Compliance Act (FATCA) online registration program is launched
…substantial fortunes overseas The U.S. Treasury Department last month postponed the start of FATCA from January to July 2014. A key part of the law involves non-U.S. banks and financial…
IRS examines jewelry, precious stones and metals businesses for compliance
…subject to the anti-money laundering program regime, (ii) businesses who purchase from the general public, and (iii) non-dealers subject to the anti-money laundering rules as long as purchases of precious…
Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A
…Sec. 5.03(5). If the trust is employer-maintained, then certain additional requirements must be met: The trust must be nondiscriminatory insofar as a wide range of employees, including rank and file…
India issues FATCA Self-certifications and KYC Warnings
…noncompliant accounts being blocked and inaccessible for any transactions. The Indian Ministry of Finance’s Central Board of Direct Taxes said in a release that “The account holders may be informed…
US Tax Treatment of a UK Self-invested personal pension (SIPP)
…additional reporting obligations for non-US trusts may arise. In fact, the treaty may not always benefit US taxpayers. In some cases, it makes sense to waive treaty benefits and include…
Parag Patel Esq. Speaks at NJCPA Seminar on”Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves”
…tax issues. We will discuss solutions for non-compliant taxpayers. Experienced tax attorney Parag Patel has handled hundreds of complex tax matters for clients. The New Jersey Society of Certified Public…
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative…
New Tax Planning Opportunities for High Income Individuals
…decreasing and rates rising. Planning Opportunities ■ Married individuals should consider establishing non-reciprocal Spousal Lifetime Access Trusts (SLATs) to protect assets from potential federal estate taxes if the federal estate…
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial…
Swiss Banks’ Deadline to Disclose Information is Extended
…banks that have a reason to believe they may have committed tax offences, defined as category two banks, have signed up to the programme. They are eligible for a non-prosecution…
“Leave a Legacy” – Beneficiary Designation on your Retirement Plan
…charitable alternative: Consider naming the RWJ Foundation as the beneficiary of your retirement plan, and use your other non-retirement plan assets, not subject to income tax, to make gifts to…
Do You Have to Pay US Taxes on Foreign Inheritance?
…report the existence of such assets. The IRS uses information reporting to determine potential tax noncompliance. Foreign inheritances come in many types and forms that require unique U.S. tax reporting:…
FATCA-Compliant Institutions List Goes Online
…nations, the requirements are beginning to take effect this year. FATCA requires foreign banks to reveal American accounts holding over $50,000. Non-compliant institutions could be frozen out of U.S. markets…
US Government Continues to Pressure Swiss Banks
…investigation. US authorities have also delivered a blow to a Swiss firm that helped Americans use insurance products to hide money. The Justice Department has reached a non-prosecution agreement with…
Estate Tax Pitfalls Seen In Court Case
…outside of wills through vehicles such as life insurance, leaving less in the estate to cover tax obligations and complicating the issue of who owes how much in taxes. Non-probate…
Pre-Immigration Income Tax Planning
…alien at the time of sale. However, a recoverable withholding tax may be applied if the seller is nonresident. A nonresident seller might wish to seek a withholding tax waiver….
FATCA Enforcement Softens
…resident in the jurisdiction in which the limited FFI (or branch) is located, and for non-participating FFIs resident in the jurisdiction FFIs that are prohibited under local law from registering…
Asset Protection – Don’t Do It Yourself
Jonathan Alper in the Florida Asset Protection Blog has a great post on how standard off the shelf LLC and estate planning forms by non-experts will generally not protect your…
Asset Protection Mistakes – 13 Tips
…Don’t co-sign or guarantee loans to family members or friends. 12. Don’t serve on the board of a non-profit organization unless it has sufficient errors and omissions insurance for directors….
Parag Patel Esq. speaks at NJCPA Tax Seminar: “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates”
…asset disclosure: who needs to file, assets that must be reported and the potential liability of the taxpayer and tax preparer Solutions for non-compliant taxpayers Basic principles of trusts and…