IRS Announces New international campaigns
On November 3, 2017, the IRS announced an additional 11 compliance campaigns as areas of focus for the Large Business & International Division (“Announcement”). The 11 newly identified campaigns focus primarily on international issues, with seven international campaigns and four
IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do
An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive
Taxpayer Tips: Best Practices for U. S. Tax Court
Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax
Beware IRS Forms W-8
Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign non-US entities or persons (citizens and corporations) in order to
IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party
The long awaited revised IRS Form W8-BEN has been recently released in July 2017. The major changes to IRS Forms W8, particularly W-8BEN-E (which is still in draft form), have been driven by the changes in the law under FATCA. The new IRS
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. IRS Revenue Procedure 92-70, specifies specific,
U.S. Tax Court: What to Expect
Reasons to Take Your Matter Before the United States Tax Court: You’ve recently undergone an audit or examination. You have taken the proper administrative steps to argue your case but still receive a notice of deficiency or notice of determination
India issues FATCA Self-certifications and KYC Warnings
The Government of India continues to crackdown on self-certifications and know your customer (KYC) compliance for financial accountholders. Earlier this month the government said that the account holders of any financial institutions need to provide self-certification of compliance under US
IRS Issues Reminders for FBARs and other International Requirements
The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At the same time, the agency advised anyone with a foreign
New Jersey Department of Revenue publishes “Manual of Audit Procedures”
On March 7th, the New Jersey Department of Revenue released its “Manual of Audit Procedures” to the public, which is intended to provide a comprehensive overview of the procedures and guidelines available to it for completing all types of audits,
Individuals with disabilities can create their own self-settled trusts
The Special Needs Trust Fairness Act provides that individuals with disabilities can now create their own special needs trusts instead of having to rely on others. The Act was included as Section 5007 of the 21st Century Cures Act which was signed into law
Avoiding and Defining Willfulness
U.S. taxpayers with unreported foreign accounts or assets are in a challenging position. The IRS has repeatedly announced that it is devoting resources to finding and penalizing taxpayers who do not disclose such offshore accounts and assets. In addition, many U.S. taxpayers,
Common Issues for US-India Tax Reporting
US-India Cooperation: In 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. Under the agreement, Indian financial
New Form Updates for Foreign Accounts
The government has made a few recent form updates regarding the filing requirements for the following forms: FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) – automatic extension granted Form 8938 (Statement of Specified Foreign Financial
IRS Letters and Notices Offering an Appeal Opportunity
There are many missed opportunities to solve tax problems with the IRS through the IRS Appeals office. Below is a list of the most common IRS letters and notices affording an IRS appeals opportunity. Letter 11 – Final Notice of
Permanent annual automatic extensions granted for FBARs to October 15
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced last week that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), of April 15 (April 18 for 2017), it will automatically
Beware of FATCA Letters
FATCA letters (sometime called Self Certification letters) are going out from banks around the world to millions of US expats in readiness for reporting their financial information to the Internal Revenue Service (IRS). If you are one of the 8
IRS Most Common Tax Notices and What They Mean
The IRS has redesigned its correspondence notices to be more “user friendly.” This is supposed to make their notices easier to understand and therefore allow responses to occur in a more effective and efficient manner. IRS tax notices will now
US Taxation of Foreign trusts: Foreign grantor trust
What is a foreign grantor trust (“FGT”). A FGT is typically used when a non-U.S. Person individual (i.e., an individual who is a non-U.S. citizen, not a “green card” holder, or otherwise not considered a U.S. income tax resident) wishes
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Recent Posts
- Make Sure You have Filed FATCA Compliance Certifications January 25, 2019
- Should I aggregate different businesses for wage and qualified property calculation purposes, or consider them to be separate on to maximize my 20% Section 199A deduction? January 25, 2019
- Should my business pay more wages or have qualified property to have a full 20% of profits Section 199A deduction, if you are a high earner taxpayer? January 23, 2019
- Is my trade or business a “Specified Service Trade or Business” and is my taxable income more than the amount that permits me to have a full 20% Section 199A deduction? January 22, 2019
- If you are a landlord, what changes need to be made to assure that you can be considered to be an active trade or business to qualify for the Section 199A deduction if you have net income from the rentals? January 21, 2019
- IRS Has New Procedures for Scrutinizing Quiet Disclosures January 15, 2019
- Significant FBAR Penalties Upheld by Court January 8, 2019
- Analysis: IRS New Disclosure Program January 4, 2019
- New IRS Voluntary Disclosure in 7 Steps December 10, 2018
- IRS Updated Voluntary Disclosure Practice is a Game-Changer December 4, 2018
- New Post-OVDP IRS Voluntary Disclosure Procedures Announced December 3, 2018
- New Jersey Tax Amnesty program November 15, 2018