Could your Organization be holding Virtual Currency that is “blockable” pursuant to OFAC’s regulations?
OFAC (Office of Foreign Asset Control) compliance applies to all US persons; including, all US citizens and permanent resident aliens regardless of their location, all persons and entities within the US, all US incorporated entities and their foreign branches, all organizations subject to US jurisdiction, foreign entities that conduct business in or with the US […]
IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations (Form 5471)
IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return. On April 16, 2019, IRS announced the approval of three additional Compliance Campaigns bringing the total of IRS Compliance Campaigns to fifty three (53). IRS Compliance […]
Your Tax Home and Travel Expense Deductions
The Internal Revenue Code (IRC) permits a U.S. Taxpayer to deduct “certain travel expenses” when traveling away from home on business. Taxpayers ought to keep close attention to a travel expense deduction and ensure that it accurately correlates with a Taxpayer’s tax home; as a travel expense deduction may attract the attention of the IRS. […]
When do you need an IRS Certifying Acceptance Agent?
When do you need an IRS Certifying Acceptance Agent? Article appeared at JD Supra on 8/15/19. There are foreign national Individuals and other foreign Persons that do not have or do not qualify for a Social Security Number (SSN) but need a Taxpayer Identification Number (TIN) to file certain tax forms and schedules including IRS […]
Does it make sense to go from an S-Corp to a C-Corp?
Does it make sense to go from an S-Corp to a C-Corp? Article appeared at JD Supra on 8/9/19. IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes. The owners of an S-Corp report the “flow-through” […]
What is an Abusive Tax Trust?
What is an Abusive Tax Trust? Article appeared at JD Supra on 8/9/19. In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and benefit. IRS has been reporting that Trusts are used for abusive tax schemes to hide true ownership of assets and income, […]
An effective compliance program can help diminish an organizational criminal fine
An effective compliance program can help diminish an organizational criminal fine. Article appeared at JD Supra on 7/30/19. On April 30, 2018, the Criminal Division of the US Department of Justice (DOJ) released a guidance document regarding corporate compliance programs. The guidance looks at the adequacy and effectiveness of compliance programs (at the time of an […]
If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)
If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA) article was published by JD Supra on 7/23/19. FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or […]
Understanding how Taxpayers may Appeal to the IRS Office of Appeals
Understanding how Taxpayers may Appeal to the IRS Office of Appeals was published by JD Supra on 7/16/19. IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is to help Taxpayers resolve their tax disputes through an informal, administrative process, and through weighting […]
Penalty of $25,000 for Foreigners with a 25% ownership stake or control of a U.S. legal entity that fail to file Form 5472
Penalty of $25,000 for Foreigners with a 25% ownership stake or control of a U.S. legal entity that fail to file Form 5472 was published by JD Supra on 7/9/19. Form 5472 is an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose […]
Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process?
Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process? was published by JD Supra on 6/25/19. An EIN is also known as a Federal Entity Tax Identification Number (EIN) and is used to identify a business entity such as a sole proprietorship, corporation, partnership, estate, trust, and other entities […]
IRS can Prove that a Taxpayer Under-Reported Income
IRS can Prove that a Taxpayer Under-Reported Income was published by JD Supra on 6/18/19. There are Taxpayers that understate income, overstate expenses and present fraudulent claims on their tax returns for credits and deductions. These Taxpayers run the risk of being identified by the IRS and having IRS determine the Taxpayer’s taxable income (taxpayer […]
