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More on Transition Tax. Including extension and waiver

On 6/4/18, IRS added 3 additional questions to the existing 14 Questions in its: “Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns”:...more

Are You Confused with Virtual Currency?

The ins and outs of virtual currency (VC) continue to challenge those who received VC for services rendered, accepted it for goods sold, bought it for investment less than a year ago, bought it for investment more than a year...more

Not Mea Culpa

There are times when Taxpayers will attempt to use the “it is not my fault” argument as a defense relating to IRS penalties. Taxpayers might argue that they relied on guidance from a tax professional or from a tax software...more

If my Virtual Currency is walking around with me, is it reportable?

Virtual Currency (VC) storage comes in the form of a “wallet” with private digital keys. The “wallets” can be domiciled in VC exchanges that operate in the US or foreign jurisdictions....more

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

Did you know that Casinos are Financial Institutions?

Since 1985, Casinos that have Gross Annual Gaming Revenues in excess of $1,000,000 are considered to be Financial Institutions and are subject to the requirements of the Bank Secrecy Act (BSA). ...more

I didn’t know that I was American

There are Individuals out there that are US Citizens (“Americans”) and they are not aware of it. Under US Tax Law, these individuals have US tax reporting responsibilities and tax obligations. These Individuals are known as...more

“File before the IRS discovers that you failed to choose the Exclusion”: words of wisdom to US Taxpayers Living Abroad

If you are a US citizen or a Permanente Resident and you live abroad, you are taxed on your worldwide income and you are considered a US Taxpayer. ...more

IRS issues a “Tax Book”

During 2017, 245 million tax returns were processed by the IRS and more than $3.4 trillion in federal taxes was paid by individuals and businesses to the US Treasury. ...more

Financial Planning Season: A way to evaluate your Provider

After the tax filing season, many Taxpayers realize that this is the right time to think about financial planning; given the fact that their financial records are updated and handy. ...more

FATCA is still Standing!

Tax Reform came and went and FATCA is still standing. While U.S. Corporations are now moving to a Territorial tax system, Individual U.S. Taxpayers living abroad ARE STILL REQUIRED to REPORT their worldwide income. ...more

Who will have the last word with Virtual Currency? IRS, FinCEN, SEC, OFAC or the CFTC?

Virtual Currency (VC) investors are currently investing without clarity regarding which Government Agency(s) has the final word with respect to the treatment of VC. US Agencies: IRS, FinCEN, SEC and CFTC – have expressed...more

Who monitors digital currency wallets?

Investors in Virtual Currency (VC) utilize the services of on-line “secure” platforms for buying, selling, transferring, and storing VC. The providers of these services are known as web-wallets (Coinbase is an example). ...more

Watch out for those who Promise Bogus Charitable Giving Tax Schemes

In the US, there are promoters of phony companies that pose as registered charities and solicit charitable contributions by individuals or corporations. The Donor will provide a receipt that is later refused by the tax...more

At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank...

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S....more

Avoid this while filing your taxes

To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns. Taxpayers want to make sure that their returns are processed correctly by the IRS. ...more

Virtual Currency Investors have a lot of responsibilities!

For U.S. Federal Income Tax purposes, Virtual Currency (VC) is treated as property. As a result, a VC investor ought to keep a very close watch on potential net short term capital gains (realized gain if VC is held one year...more

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

May I continue excluding income earned in a Foreign country after 2017?

For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA. For others, provisions of the...more

Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018. The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes...more

Los Contribuyentes con Cuentas Extranjeras No Divulgadas deben ACTUAR AHORA. El Programa de Divulgación Voluntaria de Cuentas en...

El 13 de marzo del 2018, el IRS anunció la terminación del Programa de Divulgación Voluntaria De Cuentas en el Extranjero (“OVDP”) desde el 28 de septiembre del 2018 (Notificación IR-2018-52). El OVDP ha estado disponible...more

Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more

20% Tax Deduction for Pass-Through Entities?

IRS defines Pass-Through entities as: “an entity that passes its income, loss, deductions, or credits to its owners. The owners may be partners, shareholders, beneficiaries, or investors. It usually does not have an entity...more

Understanding the “GILTI” of the Tax Reform

The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code. One of them is the tax on Global Intangible Low-Taxed Income (GILTI). Beginning with...more

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