What is a PFIC and how could your offshore investments actually lead to a higher taxation rate on earned income? A Passive Foreign Investment Company or PFIC is classified by the IRS in two ways: 75% or more of the income from the foreign corporation is classified as "passive income,"...
US Offshore Taxpayers FBAR and FATCA Still Great Concern for IRS Watchdog
A leading IRS National Taxpayer Advocate has issued her mid-year findings for 2016 last week. The report is very critical on the agency's support of US offshore taxpayers and expatriates, and focused upon the IRS' goals for the rest of 2016. The number one area of focus continues to be...
Mergers and Acquisitions In Order to Shift Corporate Taxation Offshore
There are a lot of questions around the practices made popular by Apple, Google and Microsoft regarding offshore entities and mergers and acquisitions in order to shift corporate taxation offshore to lower taxation jurisdictions. How can offshore strategies benefit small to mid-sized San Diego businesses who wish to reduce taxation...
Treasury Department and IRS Propose Changes to Offshore Business Taxes and Inversion
The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion." A hearing yesterday brought stiff resistance from representatives in the business community and others seeking to preserve offshore tax advantages. "Inversion" is one of the specific strategies addressed in the...
The IRS has Begun Data Mining for Offshore FBAR Audit Targets
It's official. The FBAR audit warnings and IRS data mining you've been reading about in this space for the past several years have been confirmed by the Wall Street Journal (WSJ): U.S. Mining Swiss Bank Data to Find Tax Cheats It wasn't a question of "if" it was a question...
What Impact will the Inspector General’s Report Have on the OVDP and Offshore IRS Violators?
The Inspector General's office recently released a scathing report accusing the IRS of missing more than $39 Million in uncollected offshore tax revenues. The report harshly criticized the IRS' complete failure to follow up on rejected OVDP and offshore IRS violators as well as internal assignment of personnel based upon...
IRS Missed $39 Million in OVDP Penalties
The US Treasury Department's Inspector General for Tax Administration has determined that the IRS missed an opportunity to collect over $39 Million in OVDP penalties from taxpayers who were either rejected or withdrew their application to the OVDP or Offshore Voluntary Disclosure Program. In a press release, Inspector General J....
FBAR Electronic Filing Due June 30 – No Extensions
If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate value exceeded $10,000 USD at any point in 2015, you are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). You must submit the FBAR...
What is the Offshore Voluntary Disclosure Program or OVDP in San Diego?
What do US taxpayers in San Diego need to know about the IRS Offshore Voluntary Disclosure Program or OVDP and how can it be the safest option for disclosing previously unreported offshore accounts, assets and income? The IRS Offshore Voluntary Disclosure Program is exactly what it sounds like - a...