A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize non-compliant taxpayers to come into compliance.” Key Takeaways Now That the IRS is Considering Updates to the Voluntary Disclosure Practice: The...
The IRS will Discover Your Offshore Financial and Digital Activities
As long as there have been taxes levied in the world, there have been those who try to work the system or evade taxes altogether. Unfortunately for many, the world has become a much smaller place for those who wish to underreport income or shelter their income and assets. The...
Why is a PFIC a Potentially Punitive Tax Consequence
What is a Passive Foreign Investment Company or PFIC, and why is a PFIC a potentially punitive tax consequence? Why is it important for any U.S. expatriate or U.S. taxpayer living or investing overseas to understand the concept of a PFIC and the implications these investments have on income tax...
IRS Continues to Tighten Focus on U.S. Cryptocurrency Investors
2025 has brought substantial new challenges as the IRS continues to tighten its focus on U.S. cryptocurrency investors. Cryptocurrency brokerages are required to report gross proceeds for each digital asset transaction they manage on IRS Form 1099-DA. This requirement applies to all digital currency transactions on or after January 1st...
How Might Marrying a Non-US Citizen Affect Your Taxes?
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit? Key Takeaways: The Ways in Which Marrying a Non-US Citizen Affect Your Taxes: The United States taxes the worldwide income...
Is the Burden of Proof on the IRS During an Audit?
Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS. Key Takeaways on Is the Burden of Proof on...
FBAR Requirements as a U.S. Person for an Offshore Account
What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties associated with non-compliance with the reporting of offshore accounts, assets and income are quite severe. Primary Takeaways Regarding FBAR Requirements as a U.S. Person or Taxpayer With...
U.S. Taxpayers with Offshore Investments Should Be Wary of PFICs
U.S. taxpayers with offshore investments should be wary of PFICs (Passive Foreign Investment Company). Many foreign nationals live and work in the United States. For those who invest in offshore companies that generate income in a passive nature (i.e. rents, royalties, interest, income from commodities or derivative trading) are permanent...
An Experienced Tax Lawyer for a California Business Tax Audit
Why do you need an experienced tax lawyer for a California business tax audit? What are some of the genuine risks during an audit of your business or professional practice? 3 Key Ideas About Why You Need a Tax Lawyer for a California Business Tax Audit It is not in...