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...
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Foreign Corporate Ownership and Investments
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, and bank accounts need an experienced U.S. international tax attorney as well as integrative business, legal, and accounting services. ...
New Deadline for FinCEN’s BOI Report is On Hold AGAIN!
UPDATE: DECEMBER 28, 2024: In the latest twist of the FinCEN Beneficial Owners Information (BOI) report, the new deadline for FinCEN's BOI Report is on hold again. On Saturday, December 28, The United States Fifth Circuit Court of Appeals reimposed the injunction imposed by a U.S. District Court in Texas...
Lack of Due Diligence During a Business Acquisition
What are the risks associated with a lack of due diligence during a business acquisition, asset purchase, stock purchase, or merger? How can due diligence make or break the success of any mergers and acquisitions transaction? Due diligence is so much less "attractive" than the deal-making portion of the transaction, and...
Trust and Estate Planning for Business Owners
Why is the end of the year a good time to consider trust and estate planning for business owners. Do you own real property or have other investments outside of your business interests? Have you given any thought to what would happen if you become ill or incapacitated and are...
Internal Revenue Service Criminal Investigation (IRS-CI) Reports Billion Dollar Impact
Internal Revenue Service Criminal Investigation (IRS-CI) recently released its Fiscal Year 2024 (FY24) Annual Report, providing insight into the types of crimes the agency is focused upon, as well as the first criminal sentences in areas of focus. Of note, the IRS-CI confirms the first time a U.S. taxpayer has...
Important News Regarding the Beneficial Owners Interest (BOI) Report
There is important news regarding the Beneficial Owners Interest (BOI) report based upon a recent District Court decision in Texas. In the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., Case No. 4:24-cv-478, the Court found that the Corporate Transparency Act (CTA) was unconstitutional and that...
Beneficial Ownership Information Form – Less than a Month to Come Into Compliance
Hopefully, by now, you’ve become aware of the Beneficial Ownership Information Form, commonly referred to as the BOI Form or BOI Report. The Financial Crimes Enforcement Network (FinCEN) finalized rules for this report late last year, and qualifying entities formed before January 1, 2024, have until January 1, 2025, to...
What is Willful Blindness According to the IRS?
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 "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...