Our Blog - Christopher J. Byrne PLLC

Estate Planning for Mixed Nationality Couples

Christopher J. Byrne – Strafford Estate Planning for Mixed Nationality Couples Webinar 2022-11-08

November 11, 2022

IRS Enforcement Issues in the News

IRS researchers and academic economists have issued a paper concluding that wealthy taxpayers may been failing to report income at a rate higher that previously estimated. The paper mentions offshore…

March 22, 2021

Wealth Taxes, Estate Taxes and the Loss of the Step Up in Basis at Death.

As discussed in an earlier post, the concept of a “Wealth Tax” has resurfaced as a possibility in the U.S. again in the form of a proposal titled the “Ultra-Millionaire…

March 18, 2021

Foreign Tax Preparation

Ultra-Millionaire Tax Act of 2021 & The Expatriation Rules

The concept of a Wealth Tax has resurfaced as a possibility in the U.S. again in recent days. It is too early to predict the likelihood of it becoming law,…

March 11, 2021

FATCA International estate planning

U.S. and Cross Border Estate Planning

The financial press has reported that the CEO of a popular video communications company has transferred $6 billion dollars’ worth of his shares of stock in a U.S. corporation. A…

March 10, 2021

Estate tax situs FDAP International Taxation International Treaty

Traditional Individual Retirement Accounts and the Estate Tax Situs Rules for a Non-Domiciliary.

As tax season heats up it is important remember that there are certain things that can still be done to impact the 2020 tax return. An important example of this…

March 8, 2021

Controlled Foreign Corporation ("CFC") FATCA Immigration Internal Revenue Code New York Nonresidents OVDI Streamlined Streamlined Procedure Tax Compliance Voluntary disclosure

Whistleblowers and The Global Reach of The IRS and NYS.

Recent headlines and articles in the financial press have been rich with inflammatory buzz words referencing “whistleblower payouts”, “indictments for tax evasion”, “state & local tax enforcement”, renewed threats of…

March 4, 2021

Compliance Issues

International Information Return Forms: Resolving Penalty Abatement Requests

The IRS has been aggressively asserting penalties for late filing of international information forms such as Form 3520, Form 3520-A, Form 5471, Form 5472, etc. This has been a very…

January 28, 2021

Foreign Tax Preparation

Panama Papers Bring First Indictments in the U.S.

On December 4, 2018, United States Federal prosecutors indicted four men in connection to the “Panama Papers” data breach first revealed in 2016. The four men were charged with tax…

December 5, 2018

Foreign Tax Preparation

IRS Announces its New Offshore Voluntary Disclosure Program.

In a memo written by Deputy Commissioner for Services and Enforcement of the IRS, Kirsten B. Wielobob, the IRS has announced a new voluntary disclosure program to begin sometime in…

December 5, 2018

Entity Classification Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance

New Form 5472 Reporting Requirements

Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business is often an overlooked form. In general, this form…

December 22, 2016

Controlled Foreign Corporation ("CFC") Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance

Dormant Foreign Corporations

A Controlled Foreign Corporation (“CFC”) is, in general, a foreign corporation controlled by a U.S. person(s) through ownership of stock. A U.S. person owning at least 10% of a CFC has a…

December 15, 2016

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