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

ABA Conference with Government Officials

The ABA recently held a conference titled National Institute on Criminal Tax Fraud and Institute on Tax Controversy.  I attended the conference where many tax attorneys and government officials discussed issues of interest. Also discussed was the effect of streamlined

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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