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Tag: Asset Protection

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

18 July, 2015

1.      FATCA (Foreign Account Tax Compliance Act of 2009) requires disclosure of your account information. A.     July 1, 2014 FATCA withholding began. B.     FATCA requires a 30 percent withholding tax on any “withholdable payment” made

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Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

13 July, 2015

We have come across the below 3 questions numerous times with our clients. What kind of evidence is relevant to demonstrate “non-willfulness” for purposes of the SDOP and the SFOP when the definition of non-willful

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India and US signed FATCA Agreement Today

9 July, 2015

India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed

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Vatican Signs FATCA Agreement

28 June, 2015

Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA).  The Vatican has become the latest FATCA signatory to share bank information with the US. The Vatican

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Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

19 June, 2015

Last we spoke at a SABANA tax section bar association educational panel “The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going” for attorneys in Orlando FL. Fellow

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Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary

27 May, 2015

There are many U.S. tax consequences to a foreign trust and a beneficiary of a foreign trust who is or becomes a U.S. citizen or resident alien. In this article it is assumed that the grantor

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The Tax Issues of Expatriation

26 May, 2015

The “United States Permanent Resident Card”, also known as a Green Card, as a work and residence permit for the USA of unlimited duration and as an immigration visa, constitutes an admission ticket to the

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A solution in a tough tax season: the IRS Streamlined Offshore Procedures

13 April, 2015

In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax

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Beware: India to sign FATCA agreement with US for sharing of information

9 April, 2015

Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian

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FATCA Repeal Fails

3 April, 2015

Last month US Senator Roger Wicker (R-Miss.) introduced a budget amendment SA 621 to repeal the Foreign Account Tax Compliance Act (FATCA)  FATCA requires foreign financial institutions to disclose to the IRS about their U.S.

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Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

2 March, 2015

With the IRS aggressively targeting taxpayers with unreported offshore accounts, tax professionals must know benefits and pitfalls of offshore accounts. Our firm presented technical seminars titled Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

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Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

31 January, 2015

IR-2015-09, Jan. 28, 2015 WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty

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