My recent blog post discussed how I approach “streamlined procedure” filings for taxpayers with unreported income, for example, from offshore assets or accounts. Often, the tax noncompliance for such cases involves unfiled international information returns as well. As discussed in the blog post, I draft the required statement of non-willfulness in such a manner that … Continue reading Is the IRS Being Reasonable when it comes to “Reasonable Cause”?
When a US person has any involvement in any way with a foreign trust, extreme care is required to make sure that all of the strict US tax filing responsibilities are met. Surprisingly, for US tax purposes, a trust can be treated as “foreign” even if it is created in the US under US laws. … Continue reading Double Whammy – US Owner and Beneficiary of Foreign Trust Held Liable for 2 Separate Penalties! Failure to Report as “Owner” and Failure to Report as “Beneficiary”