Don’t Run Afoul of U.S. Sanctions

Don’t Run Afoul of U.S. Sanctions was published by the South Florida Legal Guide.
Official Hope for the De-Risked?

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 […]
More on Transition Tax. Including extension and waiver

More on Transition Tax. Including extension and waiver On 6/4/18, IRS added 3 additional questions to the existing 14 Questions in its: “Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns” : https://www.irs.gov/newsroom/questions-and-answers-about-reporting-related-to-section-965-on-2017-tax-returns. IRS originally published these FAQs on 3/13/18 as Section 965 of the Internal Revenue Code (IRC) could give rise to […]
If my Virtual Currency is walking around with me, is it reportable?

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 […]
Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities? JD Supra 7/12/18. Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company (LLC) […]
I didn’t know that I was American

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

“File before the IRS discovers that you failed to choose the Exclusion”: words of wisdom to US Taxpayers Living Abroad – JD Supra 6/1/18. 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 […]
FATCA is still Standing!

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?

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 […]
IRS Dirty Dozen 2018 = IRS Dirty Dozen 2017

IRS Dirty Dozen 2018 = IRS Dirty Dozen 2017 published by the South Florida Legal Guide,
May I continue excluding income earned in a Foreign country after 2017?

May I continue excluding income earned in a Foreign country after 2017? – JD Supra 4/10/18. For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA. For others, provisions of the TCJA will affect […]
Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

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 […]