Taxpayers using either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, will be required to certify, that the failure to report all income, pay all tax and submit all required information returns, including FBARs (FinCEN Form 114, previously Form TD F 90-22,1) was due to Non-Willful Conduct. The IRS's OVDP Strealined Procedures…
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Mexico Issues FATCA Implementation Guidance
The second part of Resolución Miscelánea Fiscal para 2015 was published last week in the official journal and includes an "annex" concerning the rules for implementing an agreement between the Mexican Ministry of Finance (Secretaría de Hacienda y Crédito Público) and the U.S. Treasury Department regarding the FATCA regime. Annex 25 provides guidance on the…
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PLR 201504002 Allows Taxpayer to Reelect the Foreign Earned Income Exclusion
In a Private Letter Ruling (PLR) 201504002, the IRS granted a taxpayer, who has resided outside the U.S. since Year 1, the permission to re-elect the foreign earned income exclusion under Code Sec. 911(a) for Year 4 and subsequent years. Taxpayer is a United States citizen who has resided outside of the United States since…
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IRS Releases the “Dirty Dozen” Tax Scams for 2014; Offshore Income, Abusive Tax Structures & Misuse of Trusts Are On The List!!
IR-2014-16, Feb. 19, 2014WASHINGTON — The Internal Revenue Service today issued its annual “Dirty Dozen” list of tax scams, reminding taxpayers to use caution during tax season to protect themselves against a wide range of schemes ranging from identity theft to return preparer fraud. The Dirty Dozen listing, compiled by the IRS each year, lists…
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