Does investing in a PFIC make sense given FATCA reporting?

September 2017

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision.  PFICs are reportable investments and their tax regime is punitive.  Under FATCA, US Taxpayers’ undisclosed foreign financial holdings are available to IRS through

  • JD Supra

Mayweather vs. McGregor – is it about the FIGHT or is it about the TAXES? Or the Passport?

August 2017

Much has been published concerning Floyd Mayweather’s Federal Tax Liens in the amount of $22.2 Million and an unpaid 2010 IRS debt of $7.2 Million. The Jasminebrand.com released on 7/21/17 that a $3.3 million federal lien has been released by

  • 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

Will Optional GIIN Reporting on Form 8938 continue to be Optional? Or is it the beginning of a new IRS Cross-Reference?

August 2017

IRS Form 8938 (a FATCA created form) is the Statement of Specified Foreign Financial Assets in which Taxpayers are required to report their specified foreign financial assets when their value meets the obligatory reporting threshold. It has been a required

  • Wealth Strategies Journal

Methods of Proof: How IRS Can Prove That a Taxpayer Didn’t Report Income

August 7, 2017

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

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

Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

July 2017

DVD can be an option for a Taxpayer without foreign financial accounts or foreign financial issues.   It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much as possible against

  • 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

Is your Bookkeeper the Right One?

July 2017

Bookkeepers are by practical definition business multi-taskers.  They keep financial records, post debits and credits, prepare reports, execute banking transactions,  act as collectors for overdue accounts, work with clients and vendors  and handle payroll – just to name a few.  

  • JD Supra

IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

June 2017

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%.  Nonetheless, IRS has its eye on the “collections” ball.  The Agency has recently benefited from Congressional approval of more efficient

  • JD Supra