May I continue excluding income earned in a Foreign country after 2017?

April 2018

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 Expatriates

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Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

April 2018

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 https://www.jdsupra.com/legalnews/common-reporting-standard-crs-reporting-75909/

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Los Contribuyentes con Cuentas Extranjeras No Divulgadas deben ACTUAR AHORA. El Programa de Divulgación Voluntaria de Cuentas en el Extranjero se ACABA en Septiembre del 2018

March 2018

El 13 de marzo del 2018, el  IRS anunció la terminación del Programa de Divulgación Voluntaria De Cuentas en el Extranjero (“OVDP”) desde el 28 de septiembre del 2018 (Notificación IR-2018-52).  El OVDP ha estado disponible para los Contribuyentes que intencionalmente no

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Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018

March 2018

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52).  OVDP has been available to Taxpayers that willfully failed to report foreign financial assets and pay all tax due in respect

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20% Tax Deduction for Pass-Through Entities?

March 2018

IRS defines Pass-Through entities as: “an entity that passes its income, loss, deductions, or credits to its owners. The owners may be partners, shareholders, beneficiaries, or investors. It usually does not have an entity level income tax liability”.  In the

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Understanding the “GILTI” of the Tax Reform

March 2018

The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code.  One of them is the tax on Global Intangible Low-Taxed Income (GILTI).  Beginning with January 2018, a U.S. shareholder

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IRS Virtual Currency Amnesty? Not so Fast!

March 22, 2018

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Shareholders of S Corps can defer payment of Transition Tax

March 2018

The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax” regardless of whether earnings have

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Registration of Beneficial Owners: COMING TO YOU SOON?

March 2018

There is a new Bill drafted on November 14, 2017 called the Counter Terrorism and Illicit Finance Act (CTIFA).  The Bill is currently in a committee in the Senate and it proposes a substantial overhaul to the Bank Secrecy Act

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No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers

March 2018

The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. One of the Recommendations of the OTA is to

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FBARs 101

February 2018

US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities)  with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value  exceeding $10,000 at any time during the calendar year, must file FinCEN Form

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If IRS wants to obtain records held in another country, Don’t ignore its request!

February 2018

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982 (IRC 982).  https://www.jdsupra.com/legalnews/if-irs-wants-to-obtain-records-held-in-47333/  

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