International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise red flags with the IRS. The past several years have brought rapid change in FATCA compliance, and the...
The Taxpayer Bill of Rights – 10 Essential Rights for U.S. Taxpayers
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand and apply taxpayer rights throughout the process of either an IRS audit or an...
Will You Recognize the Form 1099-K When You Receive it This Year?
Will you recognize the Form 1099-K when you receive it from one or more third-party marketplace providers this year? A few years ago, the IRS implemented new reporting requirements for many popular peer-to-peer payment apps and providers, online marketplaces, ride-sharing platforms, platforms for craft or customized product producers, and even...
An Appeal of an IRS Audit is Based Upon the Audit’s Examination File
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability to put information onto "the record" to bolster...
Passing a Business or Wealth to Your Children
A well-structured trust is a central estate planning tool for small businesses and closely held family business owners when passing a business or wealth to your children. This includes heirs, beneficiaries, and future generations of your family and spouses while minimizing the impact of taxation and maximizing control. The state...
The Potential Tax Impact of Foreign Investments for U.S. Taxpayers
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys to maximizing the advantages of offshore investment involves management of the effects of taxation...
The Next Chapter in the Beneficial Ownership Information (BOI) Report Process
The Supreme Court of the United States (SCOTUS) has written the next chapter in the Beneficial Ownership Information (BOI) Report process arising out of the Corporate Transparency Act (TCA). While the requirement to file the BOI and consequences for failure to do so remain suspended at this time, SCOTUS rendered...
Important IRS and California Tax-Related Deadlines
Don't stick your head in the sand and miss important business or personal tax deadlines. Here are the important IRS and California tax-related deadlines for 2025: IRS and California Quarterly Estimated Tax Payment Due Dates for Tax Year 2025: Q4 Estimated Tax + Deferrals (2024) January 15, 2025 Q1 Estimated Tax...
A Foreign Trust Creates Complex IRS Reporting Requirements
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 foreign trust under the grantor trust rules, or are beneficiaries with an investment in a foreign...