At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank account, securities account, or brokerage account) located in a foreign country?

April 2018

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S. citizens and Resident

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Avoid this while filing your taxes

April 2018

To avoid possible scrutiny or oversight by the IRS, Accuracy is a key factor when filing Tax Returns.  Taxpayers want to make sure that their returns are processed correctly by the IRS.  Common tax filing errors such as a missing Social Security

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Virtual Currency Investors have a lot of responsibilities!

April 2018

For U.S. Federal Income Tax purposes, Virtual Currency (VC) is treated as property.  As a result, a VC investor ought to keep a very close watch on potential net short term capital gains (realized gain if VC is held one

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IRS Dirty Dozen 2018 = IRS Dirty Dozen 2017

April 2018

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Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

April 2018

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the United States.  Section 965 may give rise to a 2017 tax liability

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May I continue excluding income earned in a Foreign country after 2017?

April 2018

For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA.   For others, provisions of the TCJA will affect Expatriates

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Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

April 2018

The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018.  The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes in the Common Reporting Standard (CRS) that https://www.jdsupra.com/legalnews/common-reporting-standard-crs-reporting-75909/

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FATCA: “COPA” and “PERIODIC CERTIFICATIONS” due by July 1, 2018, will have, in effect, a 3 Month Extension. BUT, will you be READY?

April 2018

On March 19, 2018, IRS released “Draft FATCA Certification Questions” (https://www.irs.gov/businesses/corporations/draft-fatca-certifications)  to be completed by the Responsible Officer (RO) of a Participating Foreign Financial Institution (FFI) or Reporting Model 2 FFI.    The FATCA certifications are known as COPA (for certification of an Entity’s preexisting

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Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018

March 2018

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52).  OVDP has been available to Taxpayers that willfully failed to report foreign financial assets and pay all tax due in respect

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20% Tax Deduction for Pass-Through Entities?

March 2018

IRS defines Pass-Through entities as: “an entity that passes its income, loss, deductions, or credits to its owners. The owners may be partners, shareholders, beneficiaries, or investors. It usually does not have an entity level income tax liability”.  In the

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Understanding the “GILTI” of the Tax Reform

March 2018

The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code.  One of them is the tax on Global Intangible Low-Taxed Income (GILTI).  Beginning with January 2018, a U.S. shareholder

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IRS Virtual Currency Amnesty? Not so Fast!

March 22, 2018

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