If IRS wants to obtain records held in another country, Don’t ignore its request!

February 2018

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982 (IRC 982).  https://www.jdsupra.com/legalnews/if-irs-wants-to-obtain-records-held-in-47333/  

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Beware of Sales or Transfers of 10% ownership in a Foreign Corporation

February 2018

The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign corporations. https://www.jdsupra.com/legalnews/beware-of-sales-or-transfers-of-10-31885/

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Did you know that the “Act” has a Deduction for Dividends Received (DRD)?

February 2018

The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system.  Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore.  In the transition to

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U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

February 2018

The “Tax Cuts and Jobs Act” (the “Act”) has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”.  This mandatory “transition tax” or “repatriating

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Forensic Accounting and Fraud Check-Ups

February 2018

  • Business Monday 2/5/18 - South Florida Legal Guide Supplement for the Miami Herald

Did FATCA Reporting help Catch Manafort and Gates?

January 2018

  • South Florida Legal Guide 2018 Annual Edition

Conflict of Interest: When professional judgement is compromised….

January 2018

Conflicts of interest can arise at any time during a professional engagement.  According to the American Institute of Certified Public Accountants (AICPA),  “A conflict of interest may occur if a member performs a professional service for a client or employer

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The IRS’s ability to deny or revoke the Passports of Taxpayers with significant tax debts is one of the Most Serious Problems encountered by Taxpayers

January 2018

The U.S Department of State is required to deny an individual’s passport application and is authorized to revoke or limit an existing passport if the IRS has certified that the individual has seriously delinquent federal tax debt under the FAST

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BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

January 2018

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities.   The U.S. Government is determined to enforce financial transparency and combat the misuse of companies through

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Will the question for the Year 2017 be: Do you have Foreign Financial Accounts?

Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax Gap (amount of taxes owed to the

Financial Planning Should Not be “UGH”

1/8/18

  • South Florida Legal Guide - Supplement for the Miami Herald Business Monday

Why are US Citizens Renouncing their Citizenship?

January 2018

A significant number of US Taxpayers living overseas have become “unbankable” where they live because of  high account servicing costs  for local banks (Foreign Financial Institutions – also known as FFIs) caused by the requirements of FATCA.  A number of

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