News & Analysis as of

Tax Planning FinCEN

Allen Barron, Inc.

IRS and State Tax Complications of Offshore Investments

Allen Barron, Inc. on

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

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

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

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on

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

Allen Barron, Inc.

Tax Developments for US Expatriates

Allen Barron, Inc. on

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

ArentFox Schiff

The Big Six Items That Family Offices Need to Consider in 2025

ArentFox Schiff on

Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

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

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

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

Morgan Lewis

Five Developments Family Offices Are Watching in 2025

Morgan Lewis on

As family offices continue to adapt to economic, financial, and technological changes, several ongoing developments are giving family offices plenty consider heading into 2025, including gift and estate tax exemptions, which...more

Ballard Spahr LLP

New Laws for a New Year: Year-End Estate Planning in Preparation for 2025

Ballard Spahr LLP on

As 2024 quickly comes to a close, the new year will bring a change in the presidency, a new Congress, and potential changes to policies and laws that could impact individuals of all wealth levels. Going into the election,...more

PilieroMazza PLLC

Corporate Transparency Act, Part 2: Exempt Status, Physical Office, Dissolved and Tribal Entities, and Beneficial Ownership...

PilieroMazza PLLC on

The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has significant implications for government contractors, tribal entities, and commercial businesses. If you formed an entity before January 1,...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Arnall Golden Gregory LLP

2024 Brings Estate Planning Opportunities, Significant Reporting Obligations

Wealthy families should consider taking advantage of the favorable estate planning environment that 2024 brings. Next year, the estate, gift, and generation-skipping transfer tax exemptions, which are adjusted annually for...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Allen Barron, Inc.

Part 2 – International Tax Primer for US Taxpayers and Expatriates

Allen Barron, Inc. on

We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more

Allen Barron, Inc.

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Freeman Law

IRS Issues Guidance on FBAR: LB&I FBAR Practice Unit

Freeman Law on

The Bank Secrecy Act (“BSA”) requires United States persons (“USPs”) to file FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (“FBARs”), for each calendar year in which the aggregate amount(s) in certain...more

Freeman Law

Flint Demonstrates the Risks in Trying to Make a Willful IRS Streamlined Filing Non-Willful

Freeman Law on

Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure (“SFCP”) with the IRS when the facts suggest willfulness rather than...more

Freeman Law

IRS Issues FBAR Reference Guide

Freeman Law on

The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Foodman CPAs & Advisors

Upcoming Virtual Currency FBAR and FATCA Reporting Enforcement

Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR.  However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more

Freeman Law

Death Doesn’t Stop the IRS—Failure to File FBARs

Freeman Law on

Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more

Foodman CPAs & Advisors

¿Es el FinCEN “Query” la Puerta de Entrada a la Convergencia?

FinCEN es una oficina del Departamento del Tesoro de los EE. UU. Su propósito principal es proteger el sistema financiero del uso ilícito, combatir el lavado de dinero y promover la seguridad nacional a través de la...more

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