IRS Enforcement

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…

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,…

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…

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…

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…

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…

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…

Forms and Filings

Gift Inflation Adjustments in 2017

Annual gift exclusions for 2017 Form 709 United States Gift (and Generation-Skipping Transfer) Tax Return remain at $14,000 to each donee during the calendar year.  The annual exclusion for gifts…