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. ...
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...
How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...
You Sign Every Tax Return Under The Penalties of Perjury
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that they had examined the return and underlying schedules. The "Sign Here" block...
What is an FBAR and What Foreign Financial Information Are You Required to Report?
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and assets, as well as the exchange of financial information between the IRS and Foreign...
Are you Thinking of Moving to Another Country – A Few Things to Consider
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to become a U.S. expatriate. The European Union, through its official...
When to Consider the IRS Voluntary Disclosure Program
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or business assets or interests? What do you need to know about FATCA-based reporting to the IRS and how the agency...
The Tax Consequences of Offshore Mutual Funds for US Expats and Taxpayers
What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open a bank account. Almost all Foreign Financial Institutions (FFIs) require...
Questions Regarding Offshore Accounts and FBAR Filing Requirements
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US taxpayer includes all US citizens, as well as those who work or live within the...