IRS Wants Crypto Information from Foreign Countries

Last week during testimony to the Senate Finance Committee (SFC), US Internal Revenue Service Commissioner (IRS) Charles Rettig stated that Congress needs to provide clear statutory authority in order for the IRS to collect information on cryptocurrency transfers valued over US$10,000. It is believed that such transfers are generally not being reported. Cryptocurrency market capitalization … Continue reading IRS Wants Crypto Information from Foreign Countries →

Closing the International Tax Gap: IRS Doing Virtually Nothing With FATCA

Today’s blog post discusses the overall and international tax gaps, takes a look at the offshore world and how enforcement of the tax laws is faring (hint - not so good). It summarizes some important testimony given on May 11, 2021 by the Honorable J. Russell George, Treasury Inspector General for Tax Administration before the … Continue reading Closing the International Tax Gap: IRS Doing Virtually Nothing With FATCA →

FinCEN Moving Quickly to Regulate Beneficial Ownership of US Entities

On April 5th, the Financial Crimes Enforcement Network of the Treasury Department (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions pertinent to the implementation of the "Corporate Transparency Act" (CTA), enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021. The ANPRM seeks … Continue reading FinCEN Moving Quickly to Regulate Beneficial Ownership of US Entities →

Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely

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 →

Thinking of Moving Abroad? Here’s the Scoop with the Tax Girl and the Tax Lady

Looking to live under the Tuscan sun? Dreaming about Dubai? The pandemic has had many people considering a move. Many are looking at a move abroad. Kelly Phillips Erb, the @TaxGirl and I (@VLJeker , the @TaxLady_w_Style) had a great conversation about what it means from a tax and practical perspective for a US person … Continue reading Thinking of Moving Abroad? Here’s the Scoop with the Tax Girl and the Tax Lady →

FATCA 11 Years Later – US Still the Tax Haven?

Since the passage of the Foreign Account Tax Compliance Act (FATCA) in 2010, we’ve been inundated with mountains of information about this legislation including its implementing Treasury Regulations, Internal Revenue Service (IRS) announcements and notices, reams of articles, books, blog postings as well as a Twitter-verse awash with FATCA-esque tweets. Following FATCA’s roll-out, hordes of … Continue reading FATCA 11 Years Later – US Still the Tax Haven? →

Your Foreign Bank Records – IRS Now Has Much Easier Access

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 →

Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA

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 →

What a Mess: Debt Forgiveness and the American Abroad

Imagine you are an American taxpayer living overseas. Like so many other Americans you are facing financial hardships wrought by COVID-19. You have a car loan you cannot pay and mounting credit card debt. Like an angel from above, your creditors agree to forever forgive some of the amounts you otherwise owe them. You cannot … Continue reading What a Mess: Debt Forgiveness and the American Abroad →

IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

On November 5, the Internal Revenue Service (IRS) made life more difficult for taxpayers who may have missed some foreign information return filings. The IRS quietly revised one of the four options to correct for missing information returns with respect to a US taxpayer’s interest in any offshore/foreign assets and holdings (e.g., Form 8938, Form … Continue reading IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement →