U.S. expatriates should read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. This is a beneficial article published by the agency itself, detailing the unique and specific tax reporting...more
8/28/2025
/ Expatriates ,
Filing Requirements ,
FinCEN ,
Income Taxes ,
International Tax Issues ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Deductions ,
Tax Planning ,
Taxation ,
Withholding Tax
What happens if you are accused by the IRS, the FTB, or another California tax agency regarding omissions, fraud, or false information on a tax return? The short answer is simple: failure to make a full, transparent, and...more
What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more
8/21/2025
/ Compliance ,
Cross-Border Transactions ,
FBAR ,
FinCEN ,
GAAP ,
IFRS ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
State Taxes ,
Tax Liability ,
Tax Planning ,
Tax Returns
here are two sources of income tax audits in California: those initiated by the State of California Franchise Tax Board (FTB) and those based on audits conducted by another agency, such as the IRS. This second form of audit,...more
Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more
7/18/2025
/ Business Taxes ,
California ,
Enforcement Actions ,
Foreign Financial Institutions (FFI) ,
Income Taxes ,
IRS ,
Penalties ,
State Taxes ,
Tax Audits ,
Tax Liability ,
Tax Returns
Are you searching for an experienced California and IRS tax attorney? When legal professionals refer to California or IRS audits or tax issues, they are usually speaking of the types of interactions that a person or business...more
What does the substantial recent reduction in the IRS mean for U.S. taxpayers and expatriates? How will staff reductions affect the agency’s ability to audit and collect taxes owed by U.S. taxpayers around the world? What...more
Why is the statute of limitations such an essential factor in an IRS audit? Should you approve a request from the auditor for a waiver of the statute of limitations in an IRS audit? This is often a complex question, and if...more
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
6/17/2025
/ California ,
Expatriates ,
Government Agencies ,
Income Taxes ,
IRS ,
Penalties ,
State Taxes ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
6/16/2025
/ Disclosure Requirements ,
Expatriates ,
FBAR ,
FinCEN ,
International Tax Issues ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
5/30/2025
/ Appeals ,
Audits ,
Cryptocurrency ,
Filing Deadlines ,
FinCEN ,
Foreign Investment ,
Income Taxes ,
IRS ,
Litigation Strategies ,
Penalties ,
Tax Appeals ,
Tax Liability ,
Tax Planning
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more
5/27/2025
/ Business Entities ,
Disclosure Requirements ,
Filing Requirements ,
Foreign Corporations ,
International Tax Issues ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
Tax Evasion ,
Tax Liability ,
Trusts
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
4/25/2025
/ Attorney-Client Privilege ,
Audits ,
Business Ownership ,
California ,
Estate Planning ,
FBAR ,
Foreign Investment ,
International Tax Issues ,
IRS ,
Offshore Banks ,
Tax Liability ,
Tax Planning
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more
3/27/2025
/ Beneficiaries ,
Business Succession ,
Estate Planning ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
IRS ,
Probate ,
Small Business ,
Tax Planning ,
Tax Reform ,
Trusts
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more
Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year? A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps...more
2/12/2025
/ 1099s ,
eBay ,
Financial Transactions ,
FinTech ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lyft ,
Mobile Apps ,
Mobile Payments ,
PayPal ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Uber ,
Venmo
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
1/29/2025
/ Double Taxation ,
FBAR ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Tax Credits ,
Income Taxes ,
Investors ,
IRS ,
Mutual Funds ,
Offshore Banks ,
PFIC ,
Tax Credits ,
Tax Planning
Don't stick your head in the sand and miss important business or personal tax deadlines...more
1/28/2025
/ Business Taxes ,
California ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
S-Corporation ,
State Taxes ,
Tax Planning ,
Tax Returns
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
1/23/2025
/ Anti-Money Laundering ,
Beneficiaries ,
Compliance ,
FACTA ,
FBAR ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Foreign Trusts ,
Grantor Trusts ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Trusts
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
1/21/2025
/ C-Corporation ,
Compliance ,
Double Taxation ,
FinCEN ,
Foreign Corporations ,
Foreign Investment ,
GAAP ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Planning ,
Tax Treaty