US Passports: Taxpayers Should Act Before IRS Notifies The State Department

August 2018

US Taxpayers that come forward to the IRS to arrange payment of their seriously delinquent tax debt before the IRS notifies the US Department of state stand to achieve a better outcome regarding the potential revocation or denial of US

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Don’t Run Afoul of U.S. Sanctions

August 2018

  • South Florida Legal Guide Supplement Miami Herald

Official Hope for the De-Risked?

July 2018

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

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El IRS está pendiente al Cripto

July 2018

El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: “Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos”.   https://www.jdsupra.com/legalnews/el-irs-esta-pendiente-al-cripto-98046/  

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¿Quién monitorea los “wallets” de las Monedas Virtuales?

July 2018

Los inversionistas de la Moneda Virtual (MV) utilizan los servicios de plataformas en línea “seguros”  para comprar, vender, transferir y almacenar la MV.  Los proveedores de estos servicios se conocen como “wallets, billeteras o monederos web u on-line” y también

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More on Transition Tax. Including extension and waiver

June 2018

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.jdsupra.com/legalnews/more-on-transition-tax-including-55713/

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If my Virtual Currency is walking around with me, is it reportable?

June 2018

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 similarly

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

June 2018

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

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I didn’t know that I was American

June 2018

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”.   https://www.jdsupra.com/legalnews/i-didn-t-know-that-i-was-american-12567/

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“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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