The Threshold Requirements For Form 8938 While there are many different international information reporting forms that a U.S. Taxpayer may have to file, Form 8938 has become one of the most common. IRS Form 8938 refers to the reporting of Specified Foreign Financial Assets in accordance […]
Which U.S. Tax Forms to File for Foreign Retirement Plans It is very common for U.S. taxpayers who are considered U.S. persons for tax purposes to have worked or been employed in a foreign country and accumulated foreign retirement/pension over their lifetime — or possibly invested […]
What are the Form 3520-A Filing Requirements? When it comes to international tax and reporting, foreign trust tax and reporting are two of the most complicated aspects of annual foreign investment compliance. This is because of many different reasons, such as: What is a foreign trust? […]
National Taxpayer Advocate Protests IRS International Penalties For many years, our international tax law team has written numerous articles on the absolute absurdity of how the Internal Revenue Service penalizes taxpayers for the failure to report certain international information reporting forms, such as Form 3520 and […]
A Guide to Legally Moving Money Offshore Especially for taxpayers who may be new to the United States tax system, it can come as a shock and a surprise to learn that not only does the United States tax individuals on their worldwide income, but they […]
Criminal Tax Questions and Answers Oftentimes, when U.S. taxpayers make a mistake involving international tax and reporting, their knee-jerk reaction is to assume that they may have done something criminal and that the IRS Special Agents will be banging down their doors, but this is rarely […]
Was Your Streamlined Disclosure Rejected? When it comes to the Internal Revenue Service and offshore disclosure, many U.S. taxpayers can qualify to safely get into international tax and reporting compliance for previously undisclosed foreign accounts, assets, investments, and income – and regain their peace of mind […]
Tax Court Rules for IRS on $40 Million Innocent Spouse Claim In the recent case of Strom, the petitioner is the spouse of a high-income earner who petitioned the U.S. Tax Court for innocent spouse relief of more than $39 million in deficient taxes due to […]
Example of an IRS Audit for Expatriation Expatriation is the process in which a U.S. Citizen (USC) or a Long-Term Lawful Permanent Resident (LTR) formally renounces their U.S. citizenship or terminates their Lawful Permanent Resident status. For some taxpayers, the expatriation process is relatively painless. Even […]
The IRS Intensifies Focus on Offshore Tax Fraud Investigations In recent months, the Internal Revenue Service has issued various warnings to U.S. Taxpayers worldwide involved in potentially abusive and unscrupulous tax schemes. Some of the current focuses of the IRS include: Sham Trust Arrangements, Improper Use […]
Contempt for Not Repatriating Foreign Assets In this case, it is important to note that the Foreign Bank Account Reporting penalties did not stem from a criminal FBAR matter. Rather, it was a civil FBAR case that seemingly went off the rails — due to a […]
Out of all the different international information return filing requirements, Form 8938 is a relative newcomer to the world of foreign account and asset reporting. The Form 8938 is the Statement of Specified Foreign Financial Assets under 26 U.S.C. 6038D and it is filed each […]
3 Abusive Tax Arrangements While the Internal Revenue Service has a reputation for perpetually being the bad guy and going after U.S. taxpayers for every mistake they make on their taxes, there is another aspect of the IRS — which is to protect taxpayers. One of […]
The Court Upheld Form 5471 Penalties Unfortunately, U.S. taxpayers across the globe who are required to report their foreign assets to the IRS on various international information reporting forms were dealt a heavy blow by the DC Court of Appeals, when the Appellate Court reversed the […]
Deficiency Procedures Do Not Apply to Form 3520 For the past several years, the Internal Revenue Service has specifically targeted international information reporting noncompliance as a key enforcement priority. Oftentimes, U.S. taxpayers are penalized extensively for their failure to report foreign accounts, assets, investments, trusts, and […]
Choosing the Best Foreign Accounts Disclosure Lawyer Ever since the Internal Revenue Service increased its enforcement of offshore disclosure and compliance matters, many less experienced attorneys have jumped in the mix making false representations about their experience — and leading taxpayers astray. And, when these attorneys […]
IRS Foreign Account Penalty Relief For U.S. taxpayers who did not previously report all of their foreign accounts, assets, investments, and income on their tax returns and other international information reporting forms, the Internal Revenue Service offers many different offshore disclosure programs and procedures they […]
6 Key Things You Must Know For IRS Form 5471 While it would appear that there are an infinite number of international information reporting forms required for taxpayers with overseas accounts and assets, Form 5471 is one of the more common and complicated forms. That is […]
An Overview of IRS Non-Willfulness Certification The Streamlined Offshore Procedures is a program developed by the IRS to allow non-willful Taxpayers to safely disclose their previously unreported foreign accounts, assets, investments, and income. When it comes to submitting to the Streamlined Domestic Offshore Procedures or […]
Can IRS Voluntary Disclosure Limit Criminal Tax Prosecution Risks? U.S. Taxpayers who are out of compliance for failing to report foreign or domestic income and/or overseas accounts, assets, and investments have many different opportunities to safely get into compliance with the IRS. For non-willful taxpayers, there […]
Do You Bank with Banque Pictet et Cie Sa as a U.S. Person? Continuing the trend established by several Swiss banks before them, Banque Pictet has entered into a deferred prosecution agreement with the United States to minimize the damage of criminal misconduct aimed at assisting […]
How to Make Sense of PFIC 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 […]
A Form 3520 Penalty for Failure to Report a Foreign Gift At the international tax law firm of Golding & Golding, our Board-Certified Tax Law Specialist Team focuses exclusively on matters involving international tax. We have written many articles over the past several years about challenging […]
Golding & Golding’s Foreign Trust Reporting Overview When it comes to international tax and reporting, foreign trust tax and reporting are two of the most complicated aspects of annual foreign investment compliance. This is because of many different reasons, such as: What is a foreign trust? […]
Will Puerto Rico Act 60 Trigger a Tax Audit? In recent years, more and more U.S. taxpayers are seeking to circumvent certain income taxes they are required to pay as a U.S. person taxed on their worldwide income, by relocating to Puerto Rico in conjunction with […]
New Form 8300 Filing Requirements for Cash Transactions Certain businesses that conduct cash transactions over $10,000 are required to report the transactions on Form 8300. In addition, effective January 1st, 2024, the Internal Revenue Service will now require businesses to file this form electronically by e-filing […]
Form 1040-NR Filing Taxpayers who are considered U.S. Persons and required to file a tax return, are required to file an IRS Form 1040 each year to report their worldwide income. For taxpayers who are considered non-residents (usually by either making a treaty election to be […]
Foreign Money Transfers to the United States The United States tax rules can be very complicated and especially when international components are introduced into the mix, it can be downright overwhelming for U.S. Taxpayers who are not originally from the United States and/or have foreign income […]
Foreign Inheritance Form 3520 Reporting When a US Person receives an inheritance from a foreign person, a non-resident alien who has no US tax nor reporting requirement — the main requirement for the US person (not decedent) is to file a Form 3520 to disclose the […]