A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS victories regarding "willful versus non-willful" intent in FBAR related compliance cases. The unusual non-willful court decision found the US taxpayer was not "willful" when failing to report one...
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Jan Allen Speaks on a National IRS FBAR Panel Tomorrow
Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern. The topic of the expert panel discussion is "Willfulness and the IRS Disclosure Programs. Are you Compliant?" The program will answer the questions of US taxpayers and foreign nationals who live and...
What is the State of Globalization and International Business?
The Wall Street Journal recently asked an international expert the question "What is the state of globalization and international business based upon current events?" The rise of populist nationalism in the United States and around the world caused many business leaders and market observes to be concerned about the death of...
Initial Analysis of the Proposed Corporate Tax Plan on International Business and S Corporations
Our initial analysis of the proposed corporate tax plan on international business and S Corporations shows a mixed bag of moving pieces. Generally speaking, the plan calls for a corporate tax cut from the present rate of 35% to 20%. One interesting component is the replacement on the tax of...
The IRS Will Never Know About My Offshore Financial Accounts
We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they are wishing it to be true. Unfortunately, the reality of today's world is much different. The truth of the matter is shocking to many people: The IRS is...
How Should a Couple Take Title to Their Home
How should a couple take title to their home if they intend to keep it? How is the asset to be taxed after both spouses pass? Many couples keep the asset in "Joint Tenancy" which allows the asset to avoid probate upon the death of one of the spouses. Upon...
New Tax Proposal Includes a 25% Pass Through Corporate Tax
While it is far too soon to draw conclusions on Washington's proposed tax reforms, the impact on LLC and S Corporations looks to be significant. The new tax proposal includes a 25% pass through corporate tax which could affect the majority of American business owners. Pass through profits are presently...
Are There Strategies to Reduce California Tax on Large Taxable Events?
We are often asked "Are there strategies to reduce California tax on large taxable events such as selling shares of stock or settling a lawsuit?" The central answer to this question may come down to residency at the time of the transaction. The nominal tax rate in California is one...
Does Your Domestic Entity Have Foreign Assets
Does your domestic entity have foreign assets which must be reported on the IRS Form 8938? The Foreign Account Tax Compliance Act or FATCA requires many US corporations, LLCs, trusts and partnerships which hold foreign investments or financial assets to disclose them on the form 8938. If a US trust...