The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018. The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes...more
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more
The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”...more
3/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
International Tax Issues ,
New Legislation ,
S-Corporation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Liability ,
Tax Planning ,
Tax Reform
The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...more
The IRS Chief of Criminal Investigation, Don Fort, recently stated: “It’s possible to use Bitcoin and other cryptocurrencies in the same fashion as foreign bank accounts to facilitate tax evasion.” ...more
2/26/2018
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Initial Coin Offering (ICOs) ,
IRS ,
Popular ,
Tax Evasion ,
Tax Liability ,
Token Sales ,
Virtual Currency
At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982...more
La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Desde la crisis financiera mundial que comenzó en el 2007, los contribuyentes Estadounidenses e Internacionales han estado bajo un escrutinio creciente. El sistema financiero ha sido fuertemente regulado y monitoreado de...more
Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax...more
A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more
Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that...more
12/29/2017
/ 1099s ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
FATCA ,
FBAR ,
IRS ,
Popular ,
Tax Liability ,
Tax Planning ,
Virtual Currency
Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more
12/27/2017
/ 1099s ,
Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Fair Market Value ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Popular ,
Reporting Requirements ,
Section 6662 ,
Section 6722 ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
The US Tax Court is a Federal trial court established by Congress. It is independent from the IRS. The mission of Tax Court is to resolve disputes between Taxpayers and IRS. Tax Court has the authority to provide rulings on...more
In a joint tax return filing, IRS has the right to assess both spouses that sign a joint income tax return under the penalty of perjury. This is similar to jointly signing for a loan at a Bank. The Bank will impose a legal...more
As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53...more
Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more
Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%. Nonetheless, IRS has its eye on the “collections” ball. The Agency has recently benefited from...more
As we approach this year’s tax filing deadline of April 18th, do you think that you have your Tax Return under control? Before you answer yes, take the time to examine and evaluate who is preparing your taxes. Do they have...more
Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more
The IRS collection process begins when IRS does not receive full and timely payments from a taxpayer after it issues a collection notice. Based on the information in the taxpayer’s 1040 tax return, if the taxpayer does not...more