US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more
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
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting...more
For many organizations and individuals, the end of the calendar year generates significant reporting obligations, particularly with respect to the Internal Revenue Service. The following requirements may not be obvious, but...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
It’s that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs. And with each game’s conclusion spectators get an updated “playoff picture” with respect to where...more
A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death? That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more
The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more
U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000...more
All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or...more
Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more
On July 31, 2015, President Obama signed into law P.L. 114-41, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015." Although this new law was primarily designed as a 3-month stopgap extension...more
U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more