It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
3/27/2024
/ Audits ,
Bank Accounts ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FBAR ,
Financial Institutions ,
FinCEN ,
Fines ,
Foreign Assets ,
Foreign Nationals ,
GAAP ,
Investment ,
IRS ,
Offshore Banks ,
Penalties ,
Real Estate Investments ,
Swiss Banks
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
What is known as the IRS survivor’s penalty, and is there anything that can be done to provide for a surviving spouse as we age? The “survivor’s penalty” is the likelihood that a surviving spouse will face higher federal and...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers?
The value of many...more
3/19/2024
/ Cryptocurrency ,
Digital Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
Have you fully disclosed offshore cryptocurrency and NFT activities to the IRS? Earlier this month, the US Department of Justice announced the indictment of a Texas man for tax returns that were inaccurate, incomplete, or...more
2/28/2024
/ Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Disclosure Requirements ,
Fair Market Value ,
Indictments ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Listings ,
Penalties ,
Popular ,
Tax Returns
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
2/27/2024
/ Child Tax Credit ,
Expatriates ,
FBAR ,
Filing Deadlines ,
Foreign Earned Income ,
Income Taxes ,
IRS ,
Offshore Tax Informant Program (OTIP) ,
Settlement ,
Statute of Limitations ,
Tax Levy ,
Tax Returns
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
2/26/2024
/ Collection Action ,
Corporate Entities ,
Highly Compensated Employees ,
Income Taxes ,
Investigations ,
IRS ,
Large Business & International Division (LB&I) ,
Partnerships ,
Self Employed ,
Self-Employment Tax ,
Tax Audits ,
Tax Evasion ,
U.S. Treasury
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply?
The IRS Offshore Voluntary Disclosure...more
2/21/2024
/ Audits ,
Cooperation ,
Criminal Prosecution ,
Disclosure Requirements ,
Financial Institutions ,
Financial Reporting ,
Fines ,
Good Faith ,
Investment ,
IRS ,
Offshore Funds ,
Penalties ,
Tax Avoidance ,
Tax Crimes ,
Tax Evasion ,
Voluntary Disclosure
Did you know IRS tax refunds are lower for tax year 2023 thus far when compared to the same point a year ago? While the IRS just began accepting tax returns for tax year 2023 on January 29 of this year, there is already one...more
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more
Janathan Allen discusses what a tax attorney brings to the table that many other don’t. Ms. Allen notes that many attorneys don’t like numbers and yet there is so much in the business world that focuses upon the numbers...more
Is the target on short-term rental homes for new taxation? What about rental properties in general? When is income from a short-term rental presently taxable?...more
1/25/2024
/ AirBnB ,
Asset Protection ,
Commercial Property Owners ,
IRS ,
Property Tax ,
Rental Property ,
Short-Term Lease ,
Tax Code ,
Tax Deductions ,
Tax Rates ,
Tax Returns
The IRS has announced tax filing is to begin January 29, 2024 for US 2023 tax returns. Most of the almost 130 million individual tax returns will be due on Monday, April 15, 2024. The IRS will accept your tax return after...more
Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer?...more
The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more
12/20/2023
/ Business Taxes ,
C-Corporation ,
California Consumer Privacy Act (CCPA) ,
Federal Taxes ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Payment Systems ,
S-Corporation ,
State Taxes ,
Tax Returns
A recent decision in the US Tax Court affects limited partners and SECA – the Self Employed Contributions Act. In this case, Soroban Capital Partners LP (a hedge fund management company) was formed as a Delaware limited...more
12/14/2023
/ Delaware Limited Partnership Act ,
Due Process ,
IRS ,
Limited Partnerships ,
Party Presentation Principle ,
S-Corporation ,
Self Employed ,
Self-Employment Tax ,
Summary Judgment ,
Tax Code ,
Tax Court
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS?
In...more
12/13/2023
/ Artificial Intelligence ,
Audits ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FATCA ,
FBAR ,
FinCEN ,
Fines ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Partnerships ,
Swiss Banks ,
Tax Fraud ,
Tax Returns
We are often asked if one has to pay taxes when selling goods or services online. That question became even more relevant this week when the IRS postponed the new “$600 Rule.” This is a particular relief for those wo receive...more
11/30/2023
/ American Rescue Plan Act of 2021 ,
Audits ,
E-Commerce ,
Internet Retailers ,
IRS ,
Online Payments ,
PayPal ,
Popular ,
Reporting Requirements ,
Sales & Use Tax ,
Third Party Payments ,
Threshold Requirements ,
Venmo
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
11/28/2023
/ Audits ,
Automated Systems ,
Business Losses ,
Compliance ,
Cryptocurrency ,
Data Collection ,
Data Processors ,
E-Filing ,
FATCA ,
FBAR ,
Financial Institutions ,
FinCEN ,
Investors ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Funds ,
Penalties ,
Perjury ,
Reporting Requirements ,
Retirement ,
S-Corporation ,
Software ,
Tax Credits ,
Tax Deductions ,
Tax Fraud ,
Tax Preparers ,
Tax Returns ,
U.S. Treasury
Is it possible for the IRS to leave more in our paychecks in 2024? What has changed for the 2024 federal income tax brackets and how will these apply to the tax return(s) you’ll file in 2025?...more
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more
11/16/2023
/ Advance Health Care Directive ,
Alternate Investment Vehicles (AIVs) ,
Beneficiaries ,
Capital Gains Tax ,
Compliance ,
Documentation ,
Estate Planning ,
Expatriates ,
FBAR ,
FinCEN ,
Foreign Banks ,
Foreign Financial Accounts ,
Grantors ,
Income Taxes ,
Investment Portfolios ,
IRS ,
Life Insurance ,
Living Will ,
Mutual Funds ,
Passive Investments ,
Power of Attorney ,
Probate ,
Property Owners ,
Retirement Plan ,
Risk Mitigation ,
Tax Deductions ,
Tax Planning ,
Trusts
Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion. Just over the $1.765 billion jackpot claimed last month (Oct 2023). What are some tax tips for lottery winners and...more
What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
10/31/2023
/ FBAR ,
Foreign Trusts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
OVDP ,
Passive Foreign Investment Company ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Rates