IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

June 2017

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%.  Nonetheless, IRS has its eye on the “collections” ball.  The Agency has recently benefited from Congressional approval of more efficient

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FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner

June 2017

The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form.  Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the

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International Noncompliance

June 5, 2017

  • South Florida Business Journal Supplement to the Miami Herald Business Monday

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

May 2017

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents.  There are currently 43 countries on the list.  Exchange of

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Is IRS really knocking at your door?

May 2017

Generally, IRS sends a letter or a notice via regular mail notifying a Taxpayer of a potential visit.  Nonetheless, IRS may also show up unannounced at the Taxpayer’s home or place of business.    IRS wants Taxpayers to understand the reasons

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Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

May 2017

FATCA is Chapter 4 of the Internal Revenue Code (IRC).   It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government.  To enforce its conscription, it contains a mechanism for financially penalizing FFIs that

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US Banks wanting to be ahead of the FATCA game must master international tax compliance

May 2017

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks with respect to outbound payments. Many of the

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Employee Business Expenses must be Ordinary and Necessary

April 2017

Employees may be able to deduct their work related expenses as an itemized deduction.  These expenses must be unreimbursed expenses that are ordinary and necessary to their work as an employee.  According to IRS, an ordinary expense is one that

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Debit cards, Offshore Funds and a John Doe Summons

April 2017

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs.  It pursues cases in all jurisdictions of the world.  Over the years, numerous individuals have been identified as evading US taxes by hiding income in

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Colombia criminaliza la evasión fiscal

April 2017

El 12/29/2016, el Congreso de Colombia aprobó la “Ley 1819 de 2016”. La nueva legislación es una reforma tributaria estructural encaminada principalmente a aumentar los ingresos para Colombia. Colombia sufrió una pérdida de ingresos cuando los precios del petróleo se

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Colombia criminalizes Tax Evasion

April 2017

On 12/29/2016, Colombia’s Congress approved “Law 1819 of 2016”.  The new legislation is a structural tax reform primarily aimed at increasing revenues for Colombia. Colombia suffered a loss of revenues when crude oil prices plummeted beginning in 2014. The loss

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