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Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

August 2017

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful.  The definition of “Willful” or “non-willful” in Taxpayer’s conduct makes a big difference in how civil or

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Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

July 2017

DVD (Domestic Voluntary Disclosure) can be an option for a Taxpayer without foreign financial accounts or foreign financial issues.   It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much

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Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?

July 2017

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

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Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule

July 2017

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

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Do you know about FATCA international payments?

July 10, 2017

Do you know about FATCA international payments? was published by the South Florida Legal Guide.

  • South Florida Legal Guide/Miami Herald Business Monday
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Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

July 2017

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

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Is your Bookkeeper the Right One?

July 2017

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.  

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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

International Noncompliance was published by the South Florida Legal Guide.

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