Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways: The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer. It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely
Many parents establish a trust for their children and intend that the trust be a domestic (US) trust. Often, this will be a testamentary trust. That is, one that comes into being upon death of the testator, created pursuant to a Last Will & Testament. Many parents struggle with the decision as to who to … Continue reading Selecting a Trustee for Your US Trust – What About a Foreign Family Member?
COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?
The Internal Revenue Service (IRS) just issued Notice 2021-18. This is the geographical list that spells out adjustments to the foreign housing exclusion available for many US persons living abroad. These limitations are made on the basis of geographic differences in housing costs relative to housing costs in the United States. The ability to deduct … Continue reading Where Do You Live? IRS Announces 2021 Foreign Housing Cost Amounts
Please spread the word and share this news. I will be making FBAR matters simple in a cost-effective live online training session along with my colleague, Jimmy Sexton, LL.M. a fellow international tax expert. Whether you are preparing your own FBARs or those of your clients, the truth is that some FBAR situations are simple … Continue reading REMINDER: Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?
As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date. The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way
As all my readers know, the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them. Failing to file or to properly report all foreign accounts on the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts) can result in very high … Continue reading No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account
There’s a new law on the books and it does not bode well for, among others, those with foreign accounts that have not been properly reported to the Internal Revenue Service. The “Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2019” (the “Act”) became part of the reconciled National Defense Authorization Act for Fiscal … Continue reading Your Foreign Bank Records – IRS Now Has Much Easier Access
It’s finally here! We now have a new law mandating creation of a national database of beneficial owners of US businesses (and foreign businesses registered to do business in the US). It’s been a long time in coming and is being hailed as a huge anti-corruption and anti-money laundering reform . There have been several … Continue reading Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA