Contents1 How to Make Sense of PFIC2 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 […]
Contents1 Common Defenses to FBAR Violations2 Non-Willfulness3 Reasonable Cause Defense to Non-Willfulness4 Reduced Non-Willful Penalties (See IRM)5 A Warning Letter In lieu of Penalties6 Willfulness7 Is the Taxpayer Non-Willful?8 Mitigating Willful Penalties9 Pre-Penalty Avoidance with FBAR Amnesty10 Late Filing Penalties May be Reduced or Avoided11 Current […]
Contents1 A Form 3520 Penalty for Failure to Report a Foreign Gift2 26 U.S. C. 6039F3 IRS Notice 97–344 26 U.S.C. 60485 What is Form 3520?6 Who Must File Form 3520?7 What is Reported on Form 35208 When is Form 3520 Due?9 Can You Apply for […]
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 How to Avoid Common FBAR Errors2 TD 90-22.1 Form Is No Longer Used3 FBAR Is Handled Electronically4 Submit the FBAR on the FinCEN Website5 FBAR Due Date May Still Be on Automatic Extension6 It Is Not a $10,000+ Threshold for Each Account7 Signature Authority8 FBAR […]
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 a 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 […]
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 Reporting of Foreign Accounts on FBAR2 Which Foreign Accounts are Reportable3 Foreign Bank Accounts4 Foreign Investment Accounts5 Foreign Stock Certificates6 Foreign Pension Plans7 Foreign Mutual Funds8 Common International Tax Forms 9 FBAR Due Date and Extension10 Form 8938 Due Date and Extension11 Form 3520 Due Date […]
Contents1 What if You Do Not File FBAR?2 Reasonable Cause to Avoid FBAR Penalties3 Delinquent FBAR4 Non-Willful FBAR Penalties5 Willful FBAR Penalties6 Criminal Penalties7 Late Filing Penalties May be Reduced or Avoided8 Current Year vs Prior Year Non-Compliance 9 Avoid False Offshore Disclosure Submissions (Willful vs […]
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 What Can I Do if I Missed the FBAR Deadline?2 Delinquent FBAR Submission Procedures (DFSP)3 Delinquent International Information Return Submission Procedures (DIIRSP) 4 Streamlined Domestic Offshore Procedures (SDOP)5 Streamlined Foreign Offshore Procedures (SFOP)6 IRS Voluntary Disclosure Program (VDP) for Delinquent FBAR & FATCA7 Reasonable Cause for […]
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 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 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 IRS Streamlined Domestic Offshore Procedures (SDOP)2 Benefits of the Streamlined Procedures3 Purpose of IRS Streamlined Domestic Offshore Program4 Streamlined Domestic Offshore Eligibility Criteria5 Were You Non-Willful?6 Non-Willful vs. Lower Standards of Willfulness 7 Did You Previously File “Timely” Tax Returns?8 Are You Currently Under Audit or […]
Contents1 Streamlined Foreign Offshore Procedures2 Purpose of the Streamlined Foreign Offshore Procedures3 Who is Eligible for the Program?4 Other Offshore Penalties you can Avoid5 IRS Form 14653 Streamlined Foreign Non-Willful Certification 6 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)7 Need Help Finding an Experienced Offshore 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 […]