Foodman CPAs and Advisors

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

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U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax” – JD Supra. 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 charge” is […]

Conflict of Interest: When professional judgement is compromised….

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Conflict of Interest: When professional judgement is compromised…. JD Supra. 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 and the member or his […]

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

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BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)? – JD Supra. 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 […]

Why are US Citizens Renouncing their Citizenship?

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Why are US Citizens Renouncing their Citizenship? – JD Supra. 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 FFIs will not open bank […]

Bitcoins and the IRS: Reporting and Storing

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Bitcoins and the IRS: Reporting and Storing – JD Supra. Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that function in the same manner as Bitcoin and […]

Will Bankers = Law Enforcers on 5/11/18?

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Will Bankers = Law Enforcers on 5/11/18? – JD Supra. On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018.   The CDD Rule applies to Covered Financial Institutions (federally regulated banks, federally insured credit unions, mutual funds, brokers or […]

Many are now looking for IRS Guidance on Virtual Currency

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Many are now looking for IRS Guidance on Virtual Currency – JD Supra. Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance.  IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for investment; and that its sale exchange […]