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  • US Court finds non-willful FBAR penalty not limited to $10,000 per year
    Earlier this month, the U.S. District Court for the Central District of California ruled in U.S. v. Jane Boyd (No. 2:18-cv-00803) that the non-willful penalty for failing to file foreign bank account reports (FBARs) is not limited to $10,000 per year, and may be imposed on a per account basis. If a taxpayer has a reportable foreign […]
  • IRS Announces Increased Enforcement on Form 5471
    On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced a new compliance campaign to focus on the separate detach filing of Forms 5471 by US shareholders of controlled foreign corporations (CFCs) rather than attaching the form to the accompanying tax returns, so-called “loose-filed Forms 5471.” The […]
  • Welcomed Tax Relief to U.S. Individuals Owning Stock in “Controlled Foreign Corporation”
    The US Department of the Treasury last week clarified that US individual shareholders will be eligible for 50 percent relief from the new global intangible low-taxed income (GILTI) tax. GILTI was introduced by the Tax Cuts and Jobs Act 2017 (TCJA) in order to encourage large multinational enterprises to repatriate profits stored offshore. The TCJA […]
  • Consider a tax legal opinion to confirm clients’ 199A Specified Service Trades or Businesses (SSTB) status
    On Aug. 8, 2018, the IRS released proposed regulations around the centerpiece provision of the Tax Cuts and Jobs Act. The new Section 199A tax deduction provides owners of sole proprietorships, partnerships, trusts and S corporations a significant 20 percent deduction on their qualified business income (QBI) beginning in tax year 2018. In general, the deduction […]


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