Contents1 Golding & Golding’s Foreign Trust Reporting Overview2 What Is Considered to Be A Foreign Trust?3 U.S. Trust with Foreign Assets4 When is a Foreign Trust Taxable?5 Foreign Grantor and Non-Grantor Trust Beneficiary Statement6 When is a Foreign Trust Reportable?7 Does the Foreign Trust Qualify For […]
Contents1 Will Puerto Rico Act 60 Trigger a Tax Audit?2 2023 IRS Puerto Rico Act 60 Announcement 3 Non-Qualifying Income4 Not a Bona Fide Resident5 FBAR6 FATCA7 Potential Criminal Investigations as Well 8 What did Member of Congress Request 9 Late Filing Penalties May be Reduced or […]
Contents1 New Form 8300 Filing Requirements for Cash Transactions 2 Who must file3 What’s new4 When to file5 Examples of reporting situations6 Recordkeeping7 More information:8 Golding & Golding: About Our International Tax Law Firm New Form 8300 Filing Requirements for Cash Transactions Certain businesses that conduct cash […]
Contents1 IRS International Penalties and Relief2 Non-FBAR Penalty Relief3 Challenging FBAR Penalties4 Offshore Filing Procedures (Streamlined)5 Delinquent FBAR (DFSP) vs. Delinquent Forms (DIIRSP)6 Reasonable Cause7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs. Prior Year Non-Compliance 9 Avoid False Offshore Disclosure Submissions (Willful […]
Contents1 Form 1040-NR Filing2 What is Form 1040-NR?3 Can Taxpayers Itemize Deductions on Form 1040-NR?4 Which Types of Income is Reportable on a 1040-NR?5 What are the 1040-NR Due Dates?6 Dual Status Tax Returns7 Tax Payments8 Golding & Golding: An International Tax Law Firm Form 1040-NR […]
Contents1 Foreign Money Transfers to the United States2 Are Foreign Money Transfers to US Taxable Income?3 Transfers of Foreign Gift Money 4 Foreign Wire Transfer of Your Own Money to the U.S.5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs. Prior Year Non-Compliance 7 […]
Contents1 Foreign Inheritance Form 3520 Reporting2 Foreign Inheritance Form 35203 U.S. Situs4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 Golding & Golding: About Our International Tax Law Firm Foreign Inheritance […]
Contents1 What is Foreign Bank Account Reporting?2 What is the FBAR?3 Who has to file the FBAR? 4 When is the FBAR Due?5 Which Foreign Accounts do I Report?6 What Are Some Common FBAR Mistakes To Avoid?7 What are the Penalties For Missed or Incomplete FBAR?8 […]
Contents1 What is Foreign Taxable Income?2 Foreign Income from Employment3 Foreign Capital Gains4 Foreign Dividend and Interest Income5 Foreign Pension Income6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Need Help […]
Contents1 International Tax Evasion and Fraud2 Offshore Earned Income3 Offshore Passive income4 Criminal Willfulness 5 Criminal FATCA6 Submitting False Documentation7 Current Year vs Prior Year Non-Compliance 8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Need Help Finding an Experienced Offshore Tax Attorney?10 Golding & Golding: […]
Contents1 Foreign Accounts Compliance 2 Reporting FBAR to Disclose Foreign Accounts 3 Foreign Bank Accounts4 Foreign Investment Accounts5 Foreign Stock Certificates6 Foreign Pension Plans7 Foreign Mutual Funds8 Current Year vs Prior Year Non-Compliance 9 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)10 Golding & Golding: About Our […]
Contents1 All About Penalties for Tax Evasion and Tax Fraud 2 Tax Evasion is Federal Crime and a Felony3 Do I Go to Jail for Tax Evasion?4 Is Tax Fraud a Crime?5 Will I go To Jail for Tax Fraud?6 Examples of Tax Fraud or Evasion7 […]
Contents1 About the Shakira Tax Fraud Cases in Spain 2 Worldwide Income Taxes in Spain3 NRIT vs PIT4 Where was Shakira’s Primary Residence at this time?5 Golding & Golding: About Our International Tax Law Firm About the Shakira Tax Fraud Cases in Spain Unfortunately, it seems like […]
Contents1 Treaty Election for US Tax Treatment as a Non-Resident2 Tax Treaties3 Example of Non-Resident Treaty Election Clause4 Should You Make the Election?5 What About FBAR Reporting?6 The IRS Says a Treaty Election Does Not Eliminate FBAR7 FBAR Practice Unit8 FBAR Publication 55699 2023 Litigation Update […]
Contents1 Was Your Form 3520 CDP Claim Denied?2 Did Your Tax Lawyer Guarantee a Result?3 30-Day Tax Court Petition.4 Missed 30-day CDP Petition Deadline?5 Golding & Golding: About Our International Tax Law Firm Was Your Form 3520 CDP Claim Denied? The Collection Due Process Hearing (aka […]
Contents1 IRS Appeals Farhy Form 5471 Ruling 2 The Outcome of Farhy Will Have a Big Impact3 Filing Late Form 5471 4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)6 Need Help Finding an Experienced Offshore Tax Attorney?7 Golding & […]
Contents1 What is a John Doe Summons?2 IRC 76093 IRM 25.5.7.1.2 4 Who Has to Approve a John Doe Summons?5 What are the Procedures for Issuing a John Doe Summons6 John Doe Summons Must Have a Necessary Purpose7 No Notice Requirement for Enforcement8 Golding & Golding: About […]
Contents1 IRS Criminal Investigations2 Ensuring High-Income Taxpayers Pay Taxes Owed3 Making Delinquent Millionaires Pay Up4 Pursuing Tax-Evading Millionaires5 High-Dollar Scheme in Puerto Rico6 Pension Arrangements in Malta7 Cracking down on millionaire non-filers. 8 Late Filing Penalties May be Reduced or Avoided9 Current Year vs Prior Year […]
Contents1 Bad Conduct That May Lead to Prosecution2 First, Criminal vs Civil Tax Investigations3 Failure to Report Cash Income4 Failure to Report Undocumented Income5 Failure to Report Foreign Income6 Social Media Income or Benefits7 Cryptocurrency Income8 Fraudulent Transfers9 FFI FATCA Reporting10 Hiding Money Overseas11 Assigning Income […]
Contents1 Streamlined Filing Compliance Procedures 2 Purpose of the IRS Streamlined Filing Compliance Procedures3 Three Main Components to IRS Streamlined Filing Compliance Procedures4 Who is Eligible for the Streamlined Procedures5 Taxpayers Must be Non-Willful6 No Initiation of an IRS Civil Examination7 Resolving Past Delinquent Quiet Disclosure8 Tax […]
Contents1 Form 3520 Penalties and Abatement Procedure2 Late Filed Form 3520 Penalties & the IRS3 CP15 Notice of Form 3520 (6039F) Penalty4 The Attorney Files the Initial Protest5 Form 3520 Reasonable Cause Letter Rejected LTR 854C6 Would an Appeals Conference Prevent a CDP?7 Beware that CDP […]
Contents1 Form 54712 Purpose of Form 54713 Who is Required to File Form 5471?4 What is Revenue Procedure 2019-40 5 Schedule A Stock of the Foreign Corporation for 54716 Schedule B Shareholders of Foreign Corporation on Form 54717 Schedule C Income Statement for Form 54718 Schedule F […]
Contents1 Who Has a Form 3520/3520-A Filing Obligation?2 Gift from a Non-Resident Alien Individual3 Inheritance from Non-Resident Alien Individual4 Gift from a Foreign Entity5 Gifts from Foreign Related Persons6 Foreign Trust Distributions7 Ownership of a Foreign Trust8 Form 3520/3520-A Penalties9 Late Filing Penalties May be Reduced […]
Contents1 Flat-Fee Streamlined Filing Lawyers2 Low Up-Front Hourly Fee Bait-and-Switch for Streamlined Cases3 Benefits of Flat-Fee Streamlined Filing Lawyers4 International Tax Lawyer Specialist Team: Golding & Golding Flat-Fee Streamlined Filing Lawyers Flat-Fee Streamlined Filing Lawyer Fees: With the IRS having both closed OVDP (2018) and […]