Contents1 Deficiency Procedures Do Not Apply to Form 35202 Common Form 3520 Penalty Example3 Form 3520 Insanity and Absurdity Entwined4 The IRS Does Not Follow Deficiency Procedures5 Farhy and Murkhi to The Rescue, Maybe6 Late Filing Penalties May be Reduced or Avoided7 Current Year vs Prior […]
Contents1 Choosing the Best Foreign Accounts Disclosure Lawyer2 How Many Years in Practice?3 Are they a Board-Certified Tax Law Specialist?4 You Do Not Need (or Want) a Litigator For Offshore Disclosure 5 Is Your Lawyer a Case Leader or Just a Cog in the Wheel?6 Dual-licensed as […]
Contents1 IRS Foreign Account Penalty Relief2 SFCP (Streamlined Filing Compliance Procedures)3 SDOP (Streamlined Domestic Offshore Procedures)4 SFOP (Streamlined Foreign Offshore Procedures)5 DFSP (Delinquent FBAR Submission Procedures)6 DIIRSP (Delinquent International Information Return Submission Procedures)7 VDP (Voluntary Disclosure Program)8 RC (Reasonable Cause)9 Avoid Making a Quiet Disclosure (QD)10 […]
Contents1 6 Key Things You Must Know For IRS Form 54712 Are You a U.S. Person for Tax Purposes?3 Do You Even Need to File the Form 5471?4 Do You Qualify for an Exception?5 Which Category of Form 5471 Filer(s) Are You?6 Form 5471 and 8621 […]
Contents1 A Primer on IRS Tax Form 35202 Section 6039F3 Notice 97–34, Page 24 Section 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 an Extension for Form 3520?10 What […]
Contents1 An Overview of IRS Non-Willfulness Certification2 The Three Most Recent Tax Years That Have Passed3 Year-End Balance, Not Maximum Balance4 Taxpayers Must be Non-Willful5 Narrative Statements Should be Concise and Accurate6 The IRS can Still Audit Taxpayers for Prior Years7 Taxpayers Cannot Claim a Refund […]
Contents1 Can IRS Voluntary Disclosure Limit Criminal Tax Prosecution Risks?2 What Does the IRS Say?3 Full Tax Compliance is Required4 Voluntary Disclosure Timing is Important5 Late Filing Penalties May be Reduced or Avoided6 Current Year vs Prior Year Non-Compliance 7 Avoid False Offshore Disclosure Submissions (Willful […]
Contents1 Do You Bank with Banque Pictet et Cie Sa as a U.S. Person?2 Bank Enters into a Deferred Prosecution Agreement for Criminal Misconduct 3 Late Filing Penalties May be Reduced or Avoided4 Current Year vs Prior Year Non-Compliance 5 Avoid False Offshore Disclosure Submissions (Willful vs […]
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 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 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 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 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 […]