Contents1 Has the IRS Updated Foreign Gift Penalty (3520) Enforcement Procedures2 No Formal Changes to Form 3520 Enforcement Yet3 The IRS has softened its Stance on Form 3520 Enforcement 4 Taxpayer Must Show Reasonable Cause5 Late Filing Penalties May be Reduced or Avoided6 Late-Filing Disclosure Options7 Streamlined […]
Contents1 Should I Close My Unreported Foreign Accounts?2 FATCA Banks/Brokerages May Have Already Reported You3 Reverse Eggshell Audit4 You Turned a Non-Willful Violation into a Willful Violation5 Late Filing Penalties May be Reduced or Avoided6 Late-Filing Disclosure Options7 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)8 Streamlined Domestic […]
Contents1 Why Investing Offshore Leads to IRS Examinations & Fines2 Did You Get Bad Legal Advice?3 Are you FBAR Compliant?4 Are you FATCA Compliant?5 Are You Reporting Your Foreign Income?6 Did Your Foreign Bank Report You to the IRS?7 Late Filing Penalties May be Reduced or […]
Contents1 Why IRS Foreign Tax Return Enforcement Has No End Date2 26 USC 6501(c)(8) Statute of Limitations3 Section 6501(c)(8)4 Key International Provisions5 Be Careful of International Statutes of Limitations6 Fairbank Case7 Always Try to Show Reasonable Cause8 Late Filing Penalties May be Reduced or Avoided9 Current […]
Contents1 Disclosure of Foreign Assets by U.S. Taxpayers2 Foreign Bank Accounts3 Foreign Stock Accounts and Individually Held Stock4 Foreign Mutual Funds and ETFs5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore […]
Contents1 Understanding How to Navigate Form 3520 Audit Triggers2 File Form 3520 Timely3 Use Accurate Form 3520 Values4 Submit Form 3520 to the Correct IRS Office5 Late-Filing Disclosure Options6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False […]
Contents1 Understanding How to Navigate Form 8938 Audit Triggers2 First, What is FATCA?3 Form 8938 is Not the Same as FBAR4 Timely Filing: Form 8938 is Not on Automatic Extension5 Form 8938 Requires Assets and Accounts6 Do Not Intentionally Omit Accounts on Form 89387 Form 8938 […]
Contents1 How the IRS Scrutinizes Form 3520 Part IV (Gifts and Inheritance)2 Part IV Form 3520 (What is Required)3 Timeliness is Key4 Meeting the Form 3520 Threshold5 Late Filing Penalties May Be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 Avoid False Offshore Disclosure […]
Contents1 How U.S. Citizens Get Duped into Global Citizenships and Visas2 Case Study: Devin the American Who Wants to Reduce His Taxes3 They Do Not Explain About Expatriation Until After they have his Money4 Practice Tip: Giving Up Citizenship is a Big Decision for Americans5 Additional […]
Contents1 Streamlined Filing Compliance Procedures2 Non-Willfulness Requirement3 Taxpayer is Not Under Audit or Already Penalized4 Domestic Streamlined Filing Requirements5 Previously Timely Filed U.S Tax Returns 6 5% (Title 26) Offshore Penalty Instead of Multiple FBAR/Form 8938 Penalties7 Exceptions to the 5% Penalty8 Foreign Streamlined Filing Requirements9 Foreign […]
Contents1 What is Tax Avoidance vs Tax Evasion?2 Tax Avoidance3 Tax Evasion4 Late-Filing Disclosure Options5 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)6 Streamlined Domestic Offshore Procedures (SDOP, Non-Willful)7 Streamlined Foreign Offshore Procedures (SFOP, Non-Willful)8 Delinquent FBAR Submission Procedures (DFSP, Non-Willful/Reasonable Cause)9 Delinquent International Information Returns Submission Procedures […]
Contents1 IRS Passport Restrictions2 Example Language From CP508C3 Failure to File Returns (Unaware)4 Taxpayers Must Claim the Foreign Earned Income Exclusion5 Foreign Tax Credits Must Also be Claimed on the Tax Return6 What About FBAR Non-Compliance?7 Late Filing Penalties May be Reduced or Avoided8 Current Year […]
Contents1 How to Report Foreign Bank Accounts 2 FBAR (FinCEN Form 114)3 Form 8938 (FATCA)4 Form 86215 Form 35206 Form 3520-A7 Late-Filing Disclosure Options8 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)9 Streamlined Domestic Offshore Procedures (SDOP, Non-Willful)10 Streamlined Foreign Offshore Procedures (SFOP, Non-Willful)11 Delinquent FBAR Submission Procedures (DFSP, […]
Contents1 The Missed IRS Form 3520 Filing Dilemma 2 First, Will the New IRS Commissioner Accept the Proposed Changes?3 Delinquency Procedures/Reasonable Cause4 Streamlined Procedures5 About Form 3520 Filing (with Common Examples)6 Form 3520 Foreign Gift7 Form 3520 Foreign Inheritance8 Form 3520 Trust Distribution9 Form 3520/3520-A Ownership […]
Contents1 How Offshore Investment Firms Get Americans in Trouble2 Forming a Hollow Foreign Entity3 Opening Accounts Under Different Names4 Numbered or Anonymous Accounts5 How the IRS Finds You6 Quiet Disclosure vs Offshore Disclosure7 Late-Filing Disclosure Options8 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)9 Streamlined Domestic Offshore Procedures […]
Contents1 Were You Talked Into Committing Offshore Tax Evasion?2 First, Taxpayers and Tax Professionals Can Both Get into Trouble 3 IRS and FBAR Quiet Disclosure4 False Streamlined Offshore Statement5 Offshore Tax Fraud and Evasion6 Late-Filing Disclosure Options7 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)8 Streamlined Domestic Offshore Procedures […]
Contents1 FATCA Reporting2 Who Must File FATCA Form 8938?3 Key FATCA Form 8938 Threshold Requirements4 FATCA Form 8938 Filing Deadline5 What Types of Foreign Assets are Reportable?6 What if Form 8938 is Filed Late (Penalties)7 The Tip of the Iceberg8 Late Filing Penalties May be Reduced […]
Contents1 IRS Cross-Border Tax Collection and Seizures of Foreign Assets2 Whistleblower Examples3 Mutual Collection Arrangement4 Fraud Criminal Activities5 Flight Risk6 Late-Filing Disclosure Options7 Streamlined Filing Compliance Procedures (SFCP, Non-Willful)8 Streamlined Domestic Offshore Procedures (SDOP, Non-Willful)9 Streamlined Foreign Offshore Procedures (SFOP, Non-Willful)10 Delinquent FBAR Submission Procedures (DFSP, […]
Contents1 Expatriation Tax Planning for Long-Term Residents and U.S. Citizens 2 First, What is IRC Section 877A?3 Net Worth vs Exit Tax4 Mark-to-Market Gains5 Eligible Deferred Compensation6 Ineligible Deferred Compensation7 Specified Tax Deferred Accounts8 Can Gifting Avoid Exit Tax For High-Net Worth Expatriates?9 The ’3-Year Gift Pull-Back’10 […]
Contents1 Are Gifts of Foreign Cash Taxable or Reportable 2 The Purpose of Form 35203 Form 3520 Foreign Gift4 Form 3520 Foreign Inheritance5 Form 3520 Trust Distribution6 Form 3520/3520-A Ownership of Foreign Trust7 Related Persons Rules8 Trust Reporting Exceptions (2020-17 and Proposed Regulations)9 The Tip of […]
Contents1 Expatriation Tax Planning for Long-Term Residents and U.S. Citizens 2 First, What is IRC Section 877A?3 Net Worth vs Exit Tax4 Mark-to-Market Gains5 Eligible Deferred Compensation6 Ineligible Deferred Compensation7 Specified Tax Deferred Accounts8 Can Gifting Avoid Exit Tax For High-Net Worth Expatriates?9 The ’3-Year Gift Pull-Back’10 […]
Contents1 First, Beware of Fear-Mongering, Free Consultations & False Claims of Being ‘Board-Certified’2 A Taxpayer Who is New to the U.S.3 U.S. Taxpayers who Moved Overseas (FEIE and FTC)4 Other Common Reasons for Unfiled Tax Returns5 Intentional/Willful Unfiled Tax Returns6 Late-Filing Disclosure Options7 Streamlined Filing Compliance […]
Contents1 Understanding IRS Form 8621 2 First, No Form 8621 Monetary Penalty3 Not all Distributions are Excess4 Form 8621 Reporting vs FBAR5 Late Elections are Not Easy6 QEF Election Requires Specific Information7 Form 8621 is Required Even if no Tax Return8 $25,000/$50,000 Exception9 Form 8621 Attachments are […]
Contents1 FBAR (Foreign Bank and Financial Account) 2 Who Is a US Person for FBAR Purposes?3 What Is a Financial Account?4 Determining Maximum Account Value for FBAR5 What Is a Financial Interest?6 Understanding Jointly Held Account FBAR Reporting7 FBAR Exceptions to Filing8 Due Date for FBAR Filing9 […]
Contents1 Is IRS Offshore Disclosure Right For You?2 Unaware of the Foreign Account/Income Requirements3 Non-U.S. Citizens with Foreign Accounts and/or Income4 Deceased Spouse with Foreign Accounts5 Prior Foreign/Expat Tax Preparer Errors6 Prior/Current International Tax Attorney is Ineffective7 Holocaust Survivors and Descendants8 Elderly Taxpayers who Relocated to […]
Contents1 Expatriation Tax Planning for Long-Term Residents and U.S. Citizens 2 First, What is IRC Section 877A?3 Net Worth vs Exit Tax4 Mark-to-Market Gains5 Eligible Deferred Compensation6 Ineligible Deferred Compensation7 Specified Tax Deferred Accounts8 Can Gifting Avoid Exit Tax For High-Net Worth Expatriates?9 The ’3-Year Gift Pull-Back’10 […]
Contents1 Why Golding & Golding Does Not Offer Free Consultations2 Free Consultations That You Are Charged For Later by Hourly Practitioners3 Exorbitant Fees and Fear-Mongering4 What Can You Accomplish in a 15-Minute Free Consultation?5 Is a Partner Conducting the Consultation?6 Specialized Tax Law Firms vs Mills7 […]
Contents1 OVDP vs Streamlined Procedures2 First, What is OVDP/VDP?3 Willfulness and OVDP/VDP4 Streamlined Procedure Non-Willfulness Requirement5 Taxpayer is Not Under Audit or Already Penalized6 Domestic Streamlined Filing Requirements7 Previously Timely Filed U.S Tax Returns 8 5% (Title 26) Offshore Penalty Instead of Multiple FBAR/Form 8938 Penalties9 Exceptions […]
Contents1 Common Examples of IRS Foreign Noncompliance Penalty Abatement2 Pre-IRS Foreign Penalty Assessment3 FBAR Penalty Assessment4 IRS International Reasonable Cause Penalty Abatement5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs. Prior Year Non-Compliance 8 Avoid False Offshore Disclosure […]
Contents1 Moving Overseas Will Not Avoid an IRS Tax Audit 2 U.S. Person Living Abroad with U.S. Assets3 U.S. Person Living Abroad with No U.S. Assets4 U.S. Person Living Abroad in an MCAR Country5 The Tip of the Iceberg6 Late Filing Penalties May be Reduced or Avoided7 […]
Contents1 The Tax Responsibilities for New Immigrants to the United States2 Worldwide Income Taxation3 Foreign Bank Account Reporting (FBAR)4 Form 8938 (FATCA)5 Form 3520 Gift6 The Tip of the Iceberg7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs. Prior Year Non-Compliance 9 Avoid […]
Contents1 Common Examples of When Non-Resident Aliens File U.S. Taxes2 What is the Substantial Presence Test?3 H-1B Work Visa4 L-1 Transfer Visa5 B1/B2 Tourist Visa6 EB-5 Investment Visa7 F-1 Student Visa8 Closer Connection Exception9 Treaty Elections10 Late Filing Penalties May be Reduced or Avoided11 Current Year […]
Contents1 Expatriation Tax Planning for Long-Term Residents and U.S. Citizens 2 First, What is IRC Section 877A?3 Net Worth vs Exit Tax4 Mark-to-Market Gains5 Eligible Deferred Compensation6 Ineligible Deferred Compensation7 Specified Tax Deferred Accounts8 Can Gifting Avoid Exit Tax For High-Net Worth Expatriates?9 The ’3-Year Gift Pull-Back’10 […]
Contents1 Don’t Let Your Foreign Tax Non-Compliance Become Criminal2 FDAP vs ECI3 Treaty or Non-Treaty Country4 W-8 BEN to Reduce or Eliminate Withholding5 Interest Income6 Dividend Income7 Capital Gain Income8 The Tip of the Iceberg9 Late Filing Penalties May be Reduced or Avoided10 Current Year vs. […]
Contents1 The New IRS Voluntary Disclosure Practice (VDP) 2 Timing a VDP Submission is Crucial3 Taxpayers Must Certify They are ‘Willful’4 Taxpayers Must Make a Full Voluntary Disclosure5 Taxpayer Will Submit to an IRS Audit/Examination6 The Unreported Income Must Be Legally Sourced Money7 Penalty Negotiation is Limited8 […]
Contents1 Common Australian Superannuation U.S. Tax Mistakes2 Is it Taxed the Same as U.S. Social Security?3 Are Employer Superannuation Contributions Taxable in the U.S.?4 Are Voluntary Contributions Taxable?5 Australian Superannuation Withdrawal/Distribution Taxes6 Super Foreign Tax Credits for Growth7 Is Superannuation Reported as a Foreign Trust (Forms […]
Contents1 Are You Considering Expatriation?2 You Must Be Compliant Before You Terminate Status3 Five-Year Tax Compliance Rule4 What is Considered the Date of Expatriation?5 Relief Procedures Have Very Specific Eligibility Requirements6 Accidental American Status is Often the Catalyst7 401K for Net Worth vs Exit Tax8 Act […]
Contents1 Deadline to Reporting Foreign Accounts Approaches 2 No Prior Requirement to File FBAR3 First-Time Filing FBAR, Missed Other International Reporting Forms4 Missed FBAR Prior Years and Other Foreign Tax Forms5 Late Filing Penalties May Be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 Avoid […]
Contents1 For Noncompliant Taxpayers with Foreign Accounts 2 Willful vs Non-Willful3 Which Offshore Disclosure Program is Right for You?4 Timing the Foreign Account Disclosure5 Understanding the Complexity of Offshore Reporting6 Joint Accounts with Non-Disclosing Taxpayers7 Late Filing Penalties May Be Reduced or Avoided8 Current Year vs. Prior […]
Contents1 The Risk of Disclosing Foreign Account Information to Accountants2 Late Foreign Account Reporting Consultation with an Attorney3 What is the Accountant-Client Privilege for Delinquent Foreign Accounts4 Privilege Agreements Between Accountants and Attorneys are Limited5 Late Filing Penalties May Be Reduced or Avoided6 Current Year vs. […]
Contents1 How Long Should I Way Before Reporting Foreign Accounts?2 Reduce Your Stress About the Situation3 Minimize or Eliminate Offshore Penalties4 The International Tax Amnesty Programs Can Change5 Did The Taxpayer Become Willful?6 Late Filing Penalties May Be Reduced or Avoided7 Current Year vs. Prior Year […]
Contents1 When IRS Changes Course on International Penalty Enforcement2 Are the Streamlined Procedures Right for You?3 Automatically Assessed Penalties for International Violations are Common4 The Reality of IRS International Penalties5 Tax Court or District Court/Court of Claims6 Financial Limitations to Filing in Federal Court7 Late Filing […]
Contents1 What is IRS Form 8621?2 What is a PFIC?3 PFIC/CFC Crossovers, GILTI, Subpart F and Excess Distributions4 Which Forms to File to Report PFIC?5 PFIC Taxation6 Making PFIC Elections7 No PFIC Election – Excess Distributions8 Late Election/Purging PFIC Election9 Exceptions to Filing the Form 862110 […]
Contents1 Form 8833 Tax Treaty Position to the IRS2 What is Form 8833?3 Expatriation Tax Trap4 Not all Treaty Elections Require a Form 88335 Positions of which Reporting is Required6 Reporting specifically required by Form 8833 instructions7 Late Filing Penalties May Be Reduced or Avoided8 Current […]
Contents1 A Beginner’s Guide to Form 5471 Foreign Corporations2 Who has to Report Ownership in a Foreign Corporation?3 Does the Entity Qualify as a Dormant Corporation?4 Ownership Pre-dated Becoming a U.S. Person5 What is a Per Se Corporation?6 When is Form 5471 Filing Due?7 How to […]