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...
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...
IRS Updated Streamlined Filing Compliance Procedures
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you have inadvertently left off of a recent FBAR? Have you failed to file an FBAR when you otherwise...
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...
An IRS Audit Doesn’t Have to Be a Nightmare
An IRS audit doesn't have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood of the best possible outcome in an IRS...
What Happens If You Don’t File an FBAR
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US, and what happens...
Willful versus Non-Willful Conduct in the Eyes of the IRS
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how seriously the IRS takes “willful” conduct into account as it applies to an audit or tax-related investigation. ...