Tax information reporting and withholding requirements are rapidly expanding, including an increased focus on U.S. source income for foreign persons by the Internal Revenue Service, Deloitte Tax LLP said in a reportmade public Aug. 21. This change signals a new direction in the government's focus on tax compliance, Deloitte said. Taxpayers now are confronted with…
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Limited Power of Appointment Not Foolproof In Avoiding Completed Trust Gifts
Using a donors' testamentary limited power of appointment is no longer a foolproof way of guaranteeing that a transfer to a trust will not be a completed gift in the eyes of the Internal Revenue Service, Bessemer Trust officials said Aug. 21 at an American Bar Association Real Property, Trust, and Estate Law Section teleconference.…
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Former UBS Client Sentenced to Federal Prison for Failing to Report $4 Million in Swiss Bank Accounts
Willful failure to file a Form TD F 90-22.1, or Foreign Bank and Financial Accounts Report, more commonly known as an FBAR is a criminal violation of the Bank Secrecy Act. Luis A. Quintero, a former UBS Client, found that out first hand when he was sentenced recently to four months imprisonment. Luis A. Quintero,…
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Recharacterization of “Loan” to shareholder as Taxable Distribution from Corporation
The Court of Appeals for the Fifth Circuit, affirming the Tax Court, has concluded that the supposedly borrowed amount that the sole shareholder of a corporation received from a welfare benefit fund, in connection with a life insurance policy funded by the corporation, was taxable income to the shareholder and not a bona fide loan.…
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