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...
Offshore Real Estate Ownership and Tax Reporting Requirements
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to learn that the U.S. and many individual states, including California and...
International Business and Offshore Investment and Banking Create Genuine IRS Risk
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise red flags with the IRS. The past several years have brought rapid change in FATCA compliance, and the...
The Statute of Limitations for an IRS Audit
What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of their minds while filing their taxes, perhaps...
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...
When is a US Taxpayer Required to Disclose Offshore Accounts on an FBAR and Form 8938
When is a US taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number still need to understand the risk they are taking when they...
The IRS Completed the “Dirty Dozen List” for 2023
The IRS completed the “Dirty Dozen List” for 2023 and while there were a few hold-outs from previous years, there were several new warnings in the offering for 2023. The first warning focused upon the aggressive promotion of claiming Employee Retention Credit and the risk of scammers, basically warning if...
ABCast Episode 9 – International Tax Planning
Our Firm's podcast ABCast is pleased to release Episode 9 - International Tax Planning which as an overview of many legal and tax issues associated with international business, investments, financial accounts and assets. International tax planning is essential to protect your assets while minimizing the impact of taxation. The reporting...
IRS Issues 2022 Dirty Dozen Scams Warning Including Crypto and Offshore Accounts
The IRS has issued a 2022 Dirty Dozen Scams warning including crypto and offshore accounts urging US taxpayers to be aware of “bogus tax avoidance strategies.” One of the most substantial buckets referenced in the report is an attempt to use offshore accounts or digital assets such as cryptocurrency in...









