It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
3/27/2024
/ Audits ,
Bank Accounts ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FBAR ,
Financial Institutions ,
FinCEN ,
Fines ,
Foreign Assets ,
Foreign Nationals ,
GAAP ,
Investment ,
IRS ,
Offshore Banks ,
Penalties ,
Real Estate Investments ,
Swiss Banks
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
Most US homeowners and business owners understand the importance of an estate plan; they just never seem to get around to completing the task. What do you need to know about a trust? Why are trusts a central component of any...more
3/22/2024
/ Beneficiaries ,
Business Succession ,
Estate Planning ,
Grantors ,
Irrevocable Trusts ,
Living Trust ,
Probate ,
Revocable Trusts ,
Testamentary Trust ,
Trustees ,
Trusts
What is known as the IRS survivor’s penalty, and is there anything that can be done to provide for a surviving spouse as we age? The “survivor’s penalty” is the likelihood that a surviving spouse will face higher federal and...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers?
The value of many...more
3/19/2024
/ Cryptocurrency ,
Digital Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
Have you fully disclosed offshore cryptocurrency and NFT activities to the IRS? Earlier this month, the US Department of Justice announced the indictment of a Texas man for tax returns that were inaccurate, incomplete, or...more
2/28/2024
/ Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Disclosure Requirements ,
Fair Market Value ,
Indictments ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Offshore Listings ,
Penalties ,
Popular ,
Tax Returns
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
2/27/2024
/ Child Tax Credit ,
Expatriates ,
FBAR ,
Filing Deadlines ,
Foreign Earned Income ,
Income Taxes ,
IRS ,
Offshore Tax Informant Program (OTIP) ,
Settlement ,
Statute of Limitations ,
Tax Levy ,
Tax Returns
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
2/26/2024
/ Collection Action ,
Corporate Entities ,
Highly Compensated Employees ,
Income Taxes ,
Investigations ,
IRS ,
Large Business & International Division (LB&I) ,
Partnerships ,
Self Employed ,
Self-Employment Tax ,
Tax Audits ,
Tax Evasion ,
U.S. Treasury
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply?
The IRS Offshore Voluntary Disclosure...more
2/21/2024
/ Audits ,
Cooperation ,
Criminal Prosecution ,
Disclosure Requirements ,
Financial Institutions ,
Financial Reporting ,
Fines ,
Good Faith ,
Investment ,
IRS ,
Offshore Funds ,
Penalties ,
Tax Avoidance ,
Tax Crimes ,
Tax Evasion ,
Voluntary Disclosure
Did you know IRS tax refunds are lower for tax year 2023 thus far when compared to the same point a year ago? While the IRS just began accepting tax returns for tax year 2023 on January 29 of this year, there is already one...more
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more
What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need...more
1/31/2024
/ Bank Deposits ,
California ,
EDD ,
Franchise Tax Board ,
GAAP ,
Income Taxes ,
Notice of Determination (NODs) ,
Sales ,
Tax Appeals ,
Tax Audits ,
Tax Liability ,
Tax Returns
Isn’t it interesting that success is built into business succession. Still, most US companies do not have a business succession plan in place. What is business succession planning and how does it enhance your own success and...more
1/30/2024
/ Beneficiaries ,
Business Ownership ,
Business Succession ,
Estate Planning ,
Incapacitated Persons ,
Insurance Industry ,
Legal Entities ,
Legitimate Business Interest ,
Life Insurance ,
Ongoing Operations ,
Retirement ,
Revocable Trusts ,
Succession Planning ,
Tax Planning ,
Trusts
Janathan Allen discusses what a tax attorney brings to the table that many other don’t. Ms. Allen notes that many attorneys don’t like numbers and yet there is so much in the business world that focuses upon the numbers...more
Is the target on short-term rental homes for new taxation? What about rental properties in general? When is income from a short-term rental presently taxable?...more
1/25/2024
/ AirBnB ,
Asset Protection ,
Commercial Property Owners ,
IRS ,
Property Tax ,
Rental Property ,
Short-Term Lease ,
Tax Code ,
Tax Deductions ,
Tax Rates ,
Tax Returns
Why do you need estate planning no matter where you live, but especially in California? What is estate planning? Isn’t estate planning just for people with a lot of money, property and wealth? Why should someone just...more
1/17/2024
/ 401k ,
Asset Protection ,
Business Succession ,
California ,
Estate Planning ,
Executors ,
Pensions ,
Probate ,
Property Owners ,
Retirement Plan ,
Wills
Do you need an asset protection strategy in San Diego, California? What is an “Asset Protection Strategy” and who should make sure to have an asset protection strategy in place?...more
1/16/2024
/ Asset Protection ,
Asset Seizure ,
Beneficiaries ,
Business Assets ,
Business Ownership ,
Creditors ,
Heirs ,
Irrevocable Trusts ,
Landlords ,
Liability ,
Limited Liability Company (LLC) ,
Partnerships ,
Rental Property ,
Revocable Trusts ,
Risk Management ,
Strategic Planning ,
Taxation
The IRS has announced tax filing is to begin January 29, 2024 for US 2023 tax returns. Most of the almost 130 million individual tax returns will be due on Monday, April 15, 2024. The IRS will accept your tax return after...more
The Corporate Transparency Act takes effect Monday, January 1, 2024. What are the primary goals of the Corporate Transparency Act? Who is required to comply with the information disclosures within this important new law and...more
1/2/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
NDAA ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
SBA ,
Transparency
What is the importance of succession planning for business owners? Why should you be concerned about the development and implementation of succession planning if you own a business or a significant interest in an LLC, S...more
12/22/2023
/ Beneficiaries ,
Business Ownership ,
Business Succession ,
Business Taxes ,
C-Corporation ,
Capital Requirements ,
Estate Planning ,
Fees ,
Heirs ,
Life Insurance ,
Limited Liability Company (LLC) ,
Liquidity ,
Ownership Interest ,
Retirement ,
S-Corporation ,
Succession Planning ,
Trusts
Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer?...more
The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more
12/20/2023
/ Business Taxes ,
C-Corporation ,
California Consumer Privacy Act (CCPA) ,
Federal Taxes ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Payment Systems ,
S-Corporation ,
State Taxes ,
Tax Returns
What is the importance of year-end corporate governance work? I know. I can see and hear it now: most businesspeople just roll their eyes and ask, “why do I have to go through this hassle?” What is the purpose of a corporate...more
12/15/2023
/ Asset Management ,
Business Litigation ,
C-Corporation ,
Compliance ,
Corporate Governance ,
Liability ,
Limited Liability Company (LLC) ,
Operating Agreements ,
Piercing the Corporate Veil ,
S-Corporation ,
Succession Planning
A recent decision in the US Tax Court affects limited partners and SECA – the Self Employed Contributions Act. In this case, Soroban Capital Partners LP (a hedge fund management company) was formed as a Delaware limited...more
12/14/2023
/ Delaware Limited Partnership Act ,
Due Process ,
IRS ,
Limited Partnerships ,
Party Presentation Principle ,
S-Corporation ,
Self Employed ,
Self-Employment Tax ,
Summary Judgment ,
Tax Code ,
Tax Court