Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?
A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified Individuals as: US citizens Resident Aliens of the US
- JD Supra
Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule
Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or Dealers in securities; Mutual Funds; and
- Foodman CPAs & Advisors
Do you know about FATCA international payments?
Do you know about FATCA international payments? was published by the South Florida Legal Guide.
- South Florida Legal Guide/Miami Herald Business Monday
Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!
Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations are challenging for a Taxpayer in an amnesty program
- JD Supra
Is your Bookkeeper the Right One?
Bookkeepers are by practical definition business multi-taskers. They keep financial records, post debits and credits, prepare reports, execute banking transactions, act as collectors for overdue accounts, work with clients and vendors and handle payroll – just to name a few.
- JD Supra
IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections
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
- JD Supra
FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner
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
- JD Supra
International Noncompliance
International Noncompliance was published by the South Florida Legal Guide.
- 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?
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
- JD Supra
Is IRS really knocking at your door?
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
- JD Supra
Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?
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
- JD Supra
US Banks wanting to be ahead of the FATCA game must master international tax compliance
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
- JD Supra
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