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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In 2013 Capital Gains Taxes Are Going Up!
The top tax rate on long-term capital gains is currently 15%. That revelation has set off a familiar debate about whether that low rate is appropriate. Often overlooked in these discussions, however, is the fact that the days of the 15% tax rate are numbered. On January 1, 2013, capital gains taxes are scheduled to…
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Dead Beat Taxpayers Residing residing outside U.S. questioned at U.S. border regarding back taxes.
Taxpayers traveling to the United States with unpaid U.S. tax assessments can be detained at the border, questioned, and flagged for follow-up enforcement. If a taxpayer has an unpaid tax liability and is subject to a resulting Notice of Federal Tax Lien, the IRS may submit identifying taxpayer information to the Treasury Enforcement Communications System…
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