When a taxpayer has a tax increase though a civil tax audit (or examination, in IRS terminology), a taxpayer has the right to appeal that increase administratively and through court,...
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...
...the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program (OVDP), and identified the OVDP program as a most serious problem requiring resolution. The Report states that the IRS discouraged...
...investigation. For persons with undisclosed foreign accounts, KYC procedures means the likelihood of discovery is all the greater. Once the IRS identifies an individual for investigation then the Offshore Voluntary...
...$425,000 taxable income, and single filers with $400,000 of taxable income. The existing tax brackets for lower income thresholds were not changed. Long Term Capital Gains. Although the long term...
...U.S. tax laws. In signing the forms, the letter said, clients “explicitly waive banking secrecy/consent to such disclosure.” Other foreign banks also recently requested similar tax declarations from clients. Patel...
...IRS has said 33,000 U.S. taxpayers with offshore accounts have avoided prosecution since 2009 by entering a limited amnesty program, paying back taxes and identifying those who helped them hide...
...the economy no longer needs such stimulus. Extension of various tax extenders, including Child Tax Credit, Earned Income Tax Credit, American Opportunity Tax Credit, and renewable energy incentives. Stay tuned!...
...For The Possibility Of Estate Tax: The first “non-tax” recommendation is not to ignore the tax laws completely. Given the recent fluctuations in the estate tax exemption, it is wise...
...Applying Under Streamlined Procedures. Below are some of my notes: – Taxpayers who do not necessarily meet all the factors under the IRS’s streamlined filing compliance procedures for previously unreported...
...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. We welcome...
...a few planning opportunities. Tax Provisions Which May Impact Planning Opportunities ■ Medicare surtax. ■ Long term capital gains tax rate rising. ■ Federal estate tax exemption decreasing and rates...
