Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in this area based upon a significantly improved ability to process data...
A New Wave of U.S. Expatriate Income Tax Refunds?…
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be applied to offset the Net Investment Income Tax (NIIT)....
The Action Cryptocurrency Investors Need to Take Immediately
What is the action cryptocurrency investors need to take immediately? What has changed, and why should any digital asset holder or investor pay attention to this game-changing development? Here is the short answer: If you don’t take action, you will pay substantially more tax than you otherwise should on every...
The IRS Digital Asset Broker Reporting Requirements
The IRS digital asset broker reporting requirements were finalized earlier this year and impact all digital asset (i.e., cryptocurrency and Non-Fungible Tokens or NFTs) transactions beginning January 1, 2025. What do investors in digital assets need to know? How will these new regulations affect U.S. and international digital asset exchanges...
IRS Revisions to the Voluntary Disclosure Program for 2024
What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a way to come into compliance with unreported or under-reported offshore income and...
The IRS Extension Deadline is in One Week
The IRS extension deadline is in one week, Tuesday, October 15, 2024. This is the last date for most U.S. taxpayers with extensions to file their 2023 federal income tax return without incurring late filing fees and other penalties. This year there are many exceptions. The weather has presented one...
Connelly v. Internal Revenue Service is a Game Changing Decision for every U.S. Privately Held Company
Connelly v Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as from a personal estate planning point of view. The core issue of the case focused on the corporate contractual requirement...
How Did Moore v. United States Change U.S. Tax Law?
We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and whether income could be taxed before it is “realized.” The Court avoided this...
What is the “Abusive Use of Partnerships” and Why does the IRS Care?
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using sophisticated tax-free transactions that lack economic substance” to avoid paying taxes. . The IRS continues to...