New Form Updates for Foreign Accounts
...partnership’s gross income for the taxable year is passive income or at least 50 percent of the assets held by the corporation or partnership for the taxable year are assets...
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IRS Letters and Notices Offering an Appeal Opportunity
There are many missed opportunities to solve tax problems with the IRS through the IRS Appeals office. Below is a list of the most common IRS letters and notices affording...
Permanent annual automatic extensions granted for FBARs to October 15
...of April 15 (April 18 for 2017), it will automatically grant all taxpayers filing the form a six-month extension every year to Oct. 15 (which will be Oct. 16, 2017,...
ABA Conference with Government Officials
The ABA recently held a conference titled National Institute on Criminal Tax Fraud and Institute on Tax Controversy. I attended the conference where many tax attorneys and government officials discussed...
Beware of FATCA Letters
...should immediately consult a US tax attorney about filing a foreign bank account report or FBAR (Fincen 114) and Form 8938. The IRS requires these from any US taxpayer with...
New IRS IRM with Updated Streamlined Filing Compliance procedures
...IRS audits, IRS collections, IRS appeals and criminal investigations. The IRS recently internally changed the IRM for the IRS’ revised “streamlined” procedures for individuals who unintentionally fail to report foreign-source...
IRS Most Common Tax Notices and What They Mean
...adjusted the estimated tax applied to next year. It is important to alert your tax advisor of this notice because the change the IRS made affects more than one tax...
US Taxation of Foreign trusts: Foreign grantor trust
...grandchildren who are U.S. Persons. This primer explains the characteristics of FGT planning, the tax advantages of the FGT during the settlor’s lifetime, and the pitfalls of the FGT after...
FBAR Reforms Recommended
...a filing extension of their federal income tax return; FinCEN coordinate with tax preparation software vendors to ensure that both tax professionals and individual taxpayers have ready access for electronic...
5 Estate Planning Tips to Avoid Disputes
...For a will to be valid, the person making it must be able to come to his or her own decisions. If disgruntled heirs can raise doubt about whether you...
IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets
...issues to come forward to meet their tax obligations.” The IRS has developed a Streamlined Filing Compliance Procedures that is open to taxpayers who have not been willfully avoiding taxes....
Action Required: New Jersey Estate Tax is Repealed
...tax and the inheritance tax. The new legislation fails to mention whether the New Jersey Inheritance Tax, which is a completely separate tax that would remain in place and unadjusted....