Has the IRS Updated Foreign Gift Penalty (3520) Enforcement Procedures At the close of 2024, the then-acting IRS Commissioner of the Internal Revenue Service made a statement that the IRS intends to change the method for assessing 6039F (Form 3520) penalties for failing to report foreign […]
Should I Close My Unreported Foreign Accounts? In recent years, the Internal Revenue Service has made enforcement of foreign account, asset, investment, and income reporting a key compliance priority. In a now all too familiar scenario, a US Person (Citizen or Resident) will come to learn […]
Why Investing Offshore Leads to IRS Examinations & Fines While it is perfectly legal to move your money offshore, unless you remain tax compliant with your offshore investments, it may result in an IRS audit, fines, and penalties. In recent years, the number of U.S. taxpayers […]
Why IRS Foreign Tax Return Enforcement Has No End Date With the recent uptick in 2025 of taxpayers receiving penalty notices and CP508C Notices (Passport Denial or Revocation) for unreported foreign accounts, assets, and investment violations that occurred many years ago, U.S. Taxpayers must be aware […]
Disclosure of Foreign Assets by U.S. Taxpayers Each year, U.S. Taxpayers across the globe who have ownership of foreign assets, investments, accounts, trusts, entities, etc. (‘Foreign Assets’) are required to disclose their information to the IRS on various international information reporting forms. The different tax forms […]
Understanding How to Navigate Form 3520 Audit Triggers Expanding upon our recent articles about FBAR and Form 8938 triggers, Form 3520 is an IRS international tax form that is used to report foreign gifts, trusts, and inheritances to the IRS. While Golding & Golding have authored […]
Understanding How to Navigate Form 8938 Audit Triggers Expanding upon our recent article involving FBAR compliance and Form 3520 triggers, another very common international information reporting form that U.S. taxpayers may have to file is IRS Form 8938. Since the tax year 2011, certain taxpayers who […]
How the IRS Scrutinizes Form 3520 Part IV (Gifts and Inheritance) In recent years, the Internal Revenue Service has increased scrutiny of taxpayers with a Form 3520 filing requirement to disclose the receipt of a foreign gift, trust distribution, or inheritance. Even though U.S. taxpayers who […]
How U.S. Citizens Get Duped into Global Citizenships and Visas In recent years, there has been an increase in offshore and global tax and finance scams targeting wealthier Americans and U.S. Citizens. These offshore shysters promote a purported ‘tax-free offshore lifestyle’ that does not […]
Streamlined Filing Compliance Procedures When a Taxpayer is a U.S. person for tax purposes and has not previously reported their foreign income on their U.S. tax returns and failed to file accurate international information reporting forms, they may be subject to extensive IRS fines and […]
What is Tax Avoidance vs Tax Evasion? When U.S. taxpayers violate the Internal Revenue Code, oftentimes their biggest concern becomes whether they committed tax fraud or tax evasion. While tax fraud may be civil or criminal, tax evasion is a felony tax crime. Another common phrase […]
IRS Passport Restrictions When U.S. Taxpayers living in the U.S. or abroad have not complied with the Internal Revenue Service tax and reporting rules, the Internal Revenue Service has various mechanisms at their disposal to go after taxpayers to enforce tax liabilities and to collect debts. […]
How to Report Foreign Bank Accounts Individuals who are considered U.S. persons for tax purposes may have several international information reporting requirements to comply with each year to disclose their foreign accounts, assets, investments, income, trusts, and entities to the U.S. government. While many U.S. taxpayers […]
The Missed IRS Form 3520 Filing Dilemma With another tax year upon us, many individual U.S. taxpayers will learn for the first time that in prior years they may have failed to report a foreign gift, inheritance, or trust to the Internal Revenue Service on IRS […]
How Offshore Investment Firms Get Americans in Trouble Unfortunately, U.S. taxpayers with significant wealth can be a target for offshore investment companies who convince taxpayers to invest their money overseas to avoid U.S. taxes. To achieve this outcome, taxpayers will find themselves in shady situations which […]
Were You Talked Into Committing Offshore Tax Evasion? Most tax violations are civil and not criminal. That means while a taxpayer may become subject to IRS fines and penalties, they are not at risk for a potential loss of liberty such as jail or prison. However, […]
FATCA Reporting FATCA refers to the Foreign Account Tax Compliance Act. While there are many different components to FATCA, for U.S. person individuals living in either the United States or overseas the key issue is ensuring that taxpayers properly report their foreign accounts, assets, and investments […]
IRS Cross-Border Tax Collection and Seizures of Foreign Assets The United States has entered into many cooperation agreements and treaties with foreign countries, which makes it easier for them to go beyond the U.S. borders to seize accounts and assets of taxpayers who are non-compliant with […]
Expatriation Tax Planning for Long-Term Residents and U.S. Citizens One of the most common questions our international tax lawyers receive each year when U.S. Taxpayers get ready to renounce their U.S. citizenship or terminate their Lawful Permanent Resident status is whether or not they […]
Are Gifts of Foreign Cash Taxable or Reportable When it comes to reporting foreign transactions to the IRS, most U.S. taxpayers (living in the U.S. or abroad) are familiar with having to disclose foreign accounts, assets, investments, trusts, and businesses. For example, a taxpayer may own […]
Expatriation Tax Planning for Long-Term Residents and U.S. Citizens One of the most common questions our international tax lawyers receive each year when U.S. Taxpayers get ready to renounce their U.S. citizenship or terminate their Lawful Permanent Resident status is whether or not they will […]
There are many reasons why a U.S. Taxpayer (living in the U.S. or abroad) may fail to file a tax return in one year or multiple years. Oftentimes, this is common for taxpayers who are new to the United States and previously resided in a country […]
Understanding IRS Form 8621 While there are many different types of international information reporting forms that taxpayers may have to file to disclose their foreign accounts, assets, investments, and income — one of the most complicated and misunderstood forms is IRS Form 8621. Form 8621 is […]
FBAR (Foreign Bank and Financial Account) The US Government requires US Taxpayers who own foreign assets and accounts to disclose this foreign account information on FinCEN Form 114 — otherwise known as the FBAR — in addition to filing a US Tax Return. FBAR refers to […]
Is IRS Offshore Disclosure Right For You? Each year, Taxpayers who are considered U.S. Persons for tax purposes may be required to report foreign accounts, assets, investments, and income to the Internal Revenue Service and FinCEN on multiple different international information reporting forms (such as FBAR, […]
Expatriation Tax Planning for Long-Term Residents and U.S. Citizens One of the most common questions our international tax lawyers receive each year when U.S. Taxpayers get ready to renounce their U.S. citizenship or terminate their Lawful Permanent Resident status is whether or not they will have […]
Why Golding & Golding Does Not Offer Free Consultations In the world of international tax, a new tactic has emerged in which some tax law firms offer taxpayers a ‘free’ initial FBAR/FATCA/Offshore Disclosure consultation to discuss their case — but in reality, these are not ‘free’ […]
OVDP vs Streamlined Procedures With the new tax year just around the corner — and less experienced tax lawyers publishing inaccurate and ‘fear-mongering’ misinformation about IRS offshore disclosure and the streamlined procedures — our international tax law specialist team at Golding & Golding wanted to provide […]
Common Examples of IRS Foreign Noncompliance Penalty Abatement In recent years, the Internal Revenue Service has significantly increased enforcement of foreign reporting non-compliance penalties. For example, if a U.S. Taxpayer fails to report foreign accounts, assets, investments, trusts, or entities to the IRS they may become […]
Moving Overseas Will Not Avoid an IRS Tax Audit For most U.S. Taxpayers, when it comes to the IRS their biggest concern is whether the IRS can take action against them in the United States. The Internal Revenue Service has many options available to them to […]
The Tax Responsibilities for New Immigrants to the United States When foreigners first move to the United States or otherwise become U.S. persons for tax purposes, learning how to file their U.S. tax returns is not usually their main concern – especially since filing […]
Common Examples of When Non-Resident Aliens File U.S. Taxes When a U.S. Taxpayer is either a U.S. Citizen or a Lawful Permanent Resident, they are required to report their worldwide income on their U.S. tax return. This differs from most countries that only tax individuals on […]
Expatriation Tax Planning for Long-Term Residents and U.S. Citizens One of the most common questions our international tax lawyers receive each year when U.S. Taxpayers get ready to renounce their U.S. citizenship or terminate their Lawful Permanent Resident status is whether or not they will […]
Don’t Let Your Foreign Tax Non-Compliance Become Criminal When a Taxpayer is considered a U.S. person for tax purposes, they are required to report their worldwide income on their U.S. tax return. In general, a U.S. person for tax purposes includes U.S. Citizens, Lawful Permanent Residents, […]
The New IRS Voluntary Disclosure Practice (VDP) For U.S. Person Taxpayers who are out of compliance with their IRS tax and reporting requirements and want to voluntarily get into compliance, the U.S. government has developed multiple offshore tax amnesty opportunities — with the majority of […]
Common Australian Superannuation U.S. Tax Mistakes Unfortunately, the World Wide Web is riddled with misinformation about how the United States taxes Australian superannuation accounts. Self-proclaimed international tax experts claim they have an ‘expert’ understanding of how superannuation works when all they do is slap together bits […]
Are You Considering Expatriation? Each year, our international tax attorneys are contacted by U.S. Taxpayers across the globe who find themselves in the same tax predicament when it comes to expatriation. Oftentimes, the situation is the same: the Taxpayer retained a firm that claimed to be […]
Deadline to Reporting Foreign Accounts Approaches For the past several years, the FBAR has been on automatic extension. This means that U.S. Taxpayers worldwide have until October 15th to file the FBAR, even if they did not request an extension for their tax return. For most […]
For Noncompliant Taxpayers with Foreign Accounts The Internal Revenue Service has significantly increased enforcement for offshore disclosure and foreign account filing non-compliance penalties. In years past, the IRS did not routinely penalize U.S. Taxpayers for failing to report their foreign accounts — and oftentimes, the IRS […]
The Risk of Disclosing Foreign Account Information to Accountants When U.S. Taxpayers across the globe learn that they are out of compliance with the IRS and FinCEN for failing to report their foreign accounts, assets, investments, trusts, or entities, oftentimes their immediate knee-jerk reaction is to […]
How Long Should I Way Before Reporting Foreign Accounts? When a U.S. Person Taxpayer such as a U.S. citizen, Lawful Permanent Resident, or foreign national who meets the Substantial Presence Test learns that they are out of offshore tax and reporting compliance for not reporting their […]
When IRS Changes Course on International Penalty Enforcement Over the past several years, the Internal Revenue Service has significantly increased enforcement of international-related tax and reporting compliance matters. There are many different international information reporting forms that a U.S. Taxpayer may have to file when they […]
What is IRS Form 8621? While there are many complicated aspects to international tax and reporting, the IRS requirements for having to report Passive Foreign Investment Companies (PFIC) are some of the most daunting and complex. Technically, the PFIC is an acronym for Passive Foreign Investment […]
Form 8833 Tax Treaty Position to the IRS Taxpayers who are Lawful Permanent Residents and non-permanent residents who qualify as U.S. persons for tax purposes under the substantial presence test are taxed on their worldwide income similar to U.S. citizens. This is different from how most […]
A Beginner’s Guide to Form 5471 Foreign Corporations With the globalization of the U.S. economy, it is becoming increasingly common for U.S. Taxpayers to have an ownership interest in a foreign corporation — which may then require the Taxpayer to file Form 5471 to report their […]