Foodman CPAs and Advisors

Official Hope for the De-Risked?

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Official Hope for the De-Risked? was published by JD Supra on 7/25/18. Deficiencies in Anti-Money Laundering (AML) frameworks and policies have triggered a significant number of Financial Institutions (FIs) to de-risk.   The FIs that de-risk as a solution to AML deficiencies are exiting client relationships and removing or restricting banking products from their overall platform […]

If my Virtual Currency is walking around with me, is it reportable?

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If my Virtual Currency is walking around with me, is it reportable? – JD Supra 7/19/18. Virtual Currency (VC) storage comes in the form of a “wallet” with private digital keys. The “wallets” can be domiciled in VC exchanges that operate in the US or foreign jurisdictions.  VC exchanges domiciled in foreign jurisdictions that operate […]

I didn’t know that I was American

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I didn’t know that I was American – JD Supra 6/5/18. There are Individuals out there that are US Citizens (“Americans”) and they are not aware of it.  Under US Tax Law, these individuals have US tax reporting responsibilities and tax obligations.  These Individuals are known as “Accidental Americans”.    How can someone be an […]

FATCA is still Standing!

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FATCA is still Standing! was published by JD Supra on 5/17/18. Tax Reform came and went and FATCA is still standing.  While U.S. Corporations are now moving to a Territorial tax system, Individual U.S. Taxpayers living abroad ARE STILL REQUIRED to REPORT their worldwide income. Prior to the passage of The Tax Cuts and Jobs […]

At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank account, securities account, or brokerage account) located in a foreign country?

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At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank account, securities account, or brokerage account) located in a foreign country? published by JD Supra on 5/13/18. On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets […]

Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

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Common Reporting Standard (CRS) Reporting Avoidance Game Is Over – JD Supra 4/6/18. The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018.  The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes in the Common Reporting Standard (CRS) that  there are potential and […]

FATCA: “COPA” and “PERIODIC CERTIFICATIONS” due by July 1, 2018, will have, in effect, a 3 Month Extension. BUT, will you be READY?

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FATCA: “COPA” and “PERIODIC CERTIFICATIONS” due by July 1, 2018, will have, in effect, a 3 Month Extension. BUT, will you be READY? – JD Supra 5/5/18. On March 19, 2018, IRS released “Draft FATCA Certification Questions” (https://www.irs.gov/businesses/corporations/draft-fatca-certifications)  to be completed by the Responsible Officer (RO) of a Participating Foreign Financial Institution (FFI) or Reporting Model […]

No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers

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No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers – JD Supra. The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. One of the […]

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

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If IRS wants to obtain records held in another country, Don’t ignore its request! – JD Supra. 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).   […]

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 […]