US Persons and Financial Institutions: Beware when engaging financially with Venezuela

October 2017

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela.   The transactions that are prohibited by US Persons apply wherever a US Person is located. In addition, on 9/20/17, FinCEN

  • JD Supra

Here is What you Need to Do in Order to Have Stress-Free Foreign Accounts

October 2017

  • South Florida Legal Guide Supplement for the Miami Herald - Business Monday

Watch out if you are an Expatriate US Passport Holder with Tax Debt and receive Notice CP-508C!

September 2017

According to the US Department of State, there are approximately nine (9) Million US passport holders living overseas.  There continues to be a misimpression by certain US Taxpayers living overseas that they are not required to file US income tax

  • JD Supra

Out of Compliance Taxpayers: Beware of new IRS-Programs!

September 2017

The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS.  Its conviction rate of over 90% is one of the highest in federal law enforcement.  Those convicted pay taxes, penalties and interest with the Courts imposing

  • JD Supra

The OECD is focused on maintaining the integrity of the CRS

September 2017

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS).  There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53 Jurisdictions for 2018.       https://www.jdsupra.com/legalnews/the-oecd-is-focused-on-maintaining-the-44072/  

  • JD Supra

FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?

August 2017

In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application https://www.jdsupra.com/legalnews/fatca-fcpa-aml-and-ofac-allow-the-us-to-22658/  

  • JD Supra

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

  • JD Supra

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: https://www.jdsupra.com/legalnews/did-you-know-that-form-8938-filing-98759/  

  • JD Supra

Do you know about FATCA international payments?

July 10, 2017

  • South Florida Legal Guide/Miami Herald Business Monday

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

  • JD Supra

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

  • JD Supra

International Noncompliance

June 5, 2017

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