On September 23, 2015, we posted "Some Nonresidents with U.S. Assets Must File Estate Tax Returns" where we discussed that deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. Many foreigners owning property or assets in the United States are in violation of 706-NA…
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How Does CRS & FATCA Affect US Taxpayers?
On May 26, 2017 we posted Last Chance To Come Clean ... Automatic Exchange of Information Reporting Is Imminent! where we discussed that CRS participating jurisdictions began to exchange information in 2017 and returns where required to be submitted by May 31, 2017, including Crown Dependencies and Overseas Territories. We also provided a List of countries who have agreed to share…
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Disregarded Entities Are Not Always Disregarded
Under the check the box rules, entities owned by one person can often be disregarded for federal tax purposes. Such entities are referred to as "disregarded entities." As time has progressed since the passage of the check the box rules, the IRS has created more and more exceptions to the disregarded treatment. The following is…
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CPA Advice May Not Constitute Reasonable Cause to Stop FBAR Penalties
Taxpayers have been able to rely on advice from their accountants and CPAs to meet the complicated tax filing imposed by the U.S. Tax Code. But a case currently pending in the U.S. Court of Federal Claims suggests that CPA advice may not be enough to stop the IRS from assessing FBAR penalties for non-willful reporting violations.…
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