“File before the IRS discovers that you failed to choose the Exclusion”: words of wisdom to US Taxpayers Living Abroad

June 2018

If you are a US citizen or a Permanente Resident and you live abroad, you are taxed on your worldwide income and you are considered a US Taxpayer.   US citizens and Permanent Residents that live abroad may qualify to exclude from

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FATCA is still Standing!

May 2018

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

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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?

April 2018

On April 9, 2018, IRS released Notice (IR-2018-87) to remind Taxpayers that hold foreign assets of their U.S. tax obligations which could include a filing requirement and a U.S. tax liability. This Notice applies to all U.S. citizens and Resident

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Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

April 2018

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 https://www.jdsupra.com/legalnews/common-reporting-standard-crs-reporting-75909/

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FATCA: “COPA” y “CERTIFICACIONES PERIÓDICAS” que vencen el 1 de Julio de 2018 tendrán en efecto, una extensión de 3 meses. PERO, ¿estarás LISTO?

Abril 2018

El 19 de marzo de 2018, el IRS publicó el “Borrador de Preguntas de Certificación FATCA” (https://www.irs.gov/businesses/corporations/draft-fatca-certifications)  para ser completado por el Oficial Responsable (“RO”) de una  Institución Financiera Extranjera  (“FFI”) Participante,  o una FFI Modelo 2 Reportante.  Las certificaciones FATCA se conocen como “COPA”

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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?

April 2018

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 2 FFI.    The FATCA certifications are known as COPA (for certification of an Entity’s preexisting

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

March 2018

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 Recommendations of the OTA is to

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

February 2018

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).  https://www.jdsupra.com/legalnews/if-irs-wants-to-obtain-records-held-in-47333/  

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Did FATCA Reporting help Catch Manafort and Gates?

January 2018

  • South Florida Legal Guide 2018 Annual Edition

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

January 2018

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 of companies through

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

December 2018

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

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Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

November 2017

First, the Panama Papers, and now… the Paradise Papers.  The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses.   The IRS and The Department of Justice will “harvest” the names in the

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