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By: Golding & Golding, A PLC

Latest from International Tax Blog - Page 2

Form 3520 Foreign Inheritance Form 3520 Inheritance Form 3520 Inheritance: The IRS Form 3520 is used to report certain foreign transactions involving gifts and trusts. So, why are Foreign Inheritances included in the filing requirements? That is because technically an inheritance is a gift. Despite the fact that the IRS has promulgated many, many laws detailing the difference between a gift and inheritance (for example, “Step-Up Basis”), for Form 3520, they all mush together. Therefore, if you…
?   Expatriation for Citizens and Long-Term Residents Expatriation for Citizens & Long-Term Residents What is Expatriation for Citizen & Long-Term Residents? Expatriation is a simple, but complex undertaking. Oftentimes, when discussing the concept of expatriation and the IRS, there are very specific issues which need to be addressed, such as Long-Term Resident status, Covered Expatriate status, and Mark-to-Market elections. For purposes of this summary, we will introduce the basics of the process of…
IRS Special Agents and Offshore Non-Compliance Special Agents, Offshore Tax Crimes & IRS Audits Special Agents, Offshore Tax Crime and IRS Investigations: When the IRS Special Agents visit you, they mean business. Unlike other general positions like an examiner or agent (where not tax or legal experience is required) — IRS Special Agents are specially trained. When the IRS believes someone may have committed a tax crime, the matter is referred to the IRS Special…
  Abandonment of Green Card, Expatriation and Exit Tax Green Card Abandonment Green Card Abandonment: For many Legal Permanent Residents, once they learn about the IRS tax liabilities for being a Green Card Holder, along with the potential future exit tax, being a U.S. person loses its luster. As a result, the green card holder wants to abandon their green card status and give up their U.S. Person status. Whether or not the person…
  FBAR Quiet Disclosure What is a FBAR Quiet Disclosure? FBAR Quiet Disclosure: An FBAR quiet disclosure puts U.S. taxpayers at serious risk. The FBAR is a FinCEN form (114) that is used by U.S. persons who have foreign accounts, assets, or investments — and meet the threshold requirements for filing the form. When a person has not filed the form, there are offshore disclosure procedures in place to assist with filing. If a…
Immigration Tax Lawyers Immigration & Tax Lawyers  Immigration Tax Lawyers: When foreigners become U.S. Persons for tax purposes, the submitting of tax returns, FBAR, FATCA, and other international information returns can become very complicated. While the tax rules are always changing, the IRS has honed in on foreign accounts compliance as a key enforcement priority. This can be even more confusing for visa holders who meet the substantial presence test, and legal permanent residents…
IRC 965 International Compliance Campaign What is the IRC 965 International Compliance Campaign? IRC 965 International Compliance Campaign: Each year, the IRS introduces several new international enforcement campaigns. The purpose of these campaigns is to put Taxpayers on notice of certain tax issues of which the Internal Revenue Service will prioritize when it comes to enforcement. Back on July 6, 2020, the IRS introduced a new IRC 965 International Compliance Campaign. IRC 965 is the…
Offshore Bank Accounts, Divorce & the IRS Offshore Bank Accounts, Divorce & the IRS Offshore Bank Accounts & Divorce: Many years ago while I was in Law School (which seems like forever-ago), I clerked for a former Chief Judge for Virginia State. He was an incredible attorney, and he taught me one very important tool for the effective practice of law. It’s always ready, aim, fire — not ready, fire aim. More often than not,…
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Civil Tax Fraud Penalty Civil Tax Fraud Penalty & the IRS Civil Tax Fraud Penalty: While some tax violations are not necessarily a big deal, IRS Tax Fraud Penalties are tough. With Civil Tax Fraud, the penalties can reach upwards of 75% of the tax liability. In addition, the penalties can lead to even worse penalties, including a potential IRS Special Agent Investigation.   The reason is because in addition to monetary penalties, the stigma…
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FBAR for Disregarded Entities FBAR Filing for Disregarded Entities FBAR Filing forDisregard Entities: The IRS does not limit FBAR reporting to individuals. Rather, the U.S. Government requires all U.S. persons (including entities and disregarded entities) to file the FBAR. And, with the Internal Revenue Service taking an aggressive position of matters involving the enforcement foreign accounts compliance, it is important to file the necessary reporting forms, and/or consider amnesty and voluntary disclosure if you…