International Tax Law Archives - Page 17 of 27

Are there conflicting signals from IRS as it relates to Section 965?

February 2020

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017. The sections requires a United States shareholder to pay a transition tax on the

JD Supra and Foodman Website

IRS issues FATCA Relief but not for All

January 2020

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens. These are procedures for certain persons who have relinquished, or intend to relinquish, their United States citizenship, who wish to come into compliance with their U.S. income tax

JD Supra and Foodman Website

IRS “BEEFS UP” Section 965 COMPLIANCE for 2017 and 2018 Returns

November 2019

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are required to pay a “transition

Foodman CPAs & Advisors and JD Supra

Los Contadores Forenses son “Detectives Privados”

November 2019

El entorno actual de cambio creciente, las presiones económicas, la globalización, la tecnología, el gobierno corporativo, el cumplimiento y la complejidad de las transacciones financieras son las fuerzas impulsoras del inicio del fraude. Además, la desesperación económica, un solo evento

Foodman CPAs & Advisors website and JD Supra

Indirect linkages to Tax Havens

November 2019

The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report all or some of

Foodman CPAs & Advisors

An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

November 2019

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal Revenue Manual (IRM), circumstances exist when attorney client

Foodman CPAs & Advisors website

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

October 2019

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive infrastructure inside the LBI. The campaigns require strategic

Foodman CPAs & Advisors

Automatic Exchange of Information leads to Deposit Drops at International Financial Centers

October 2019

On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on cross-border financial activity using

Foodman CPAs & Advisors

Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?

September 2019

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the TA’s request for the

Foodman CPAs & Advisors

IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations (Form 5471)

September 2019

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

Foodman CPAs & Advisors

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

July 2019

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

JD Supra

IRS can Prove that a Taxpayer Under-Reported Income

June 2019

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