Category: Featured Articles

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How much did Colin Kaepernick actually receive from his “opting out” of the contract with the San Francisco Giants following the 2016 season and the recent  Collective Bargaining Agreement, (CBA), with the NFL.[1] 

In a recent interview between Kaepernick’s attorney, Mark Geragos and CNN’s Ana Cabrera, Geragos clarified that the disagreement was resolved through the CBA with a Confidentiality Agreement for a undisclosed amount with speculation between $20 Million and $100 Million. [2]  

However, no one is saying anything about what the final amount was agreed upon.  Lets put forth a few scenarios with the possibility that one could be close to the negotiating  amount.  

Here is what is known, the NFL possibly pa

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So, this year you are preparing your own tax return, no need for a CPAs, Enrolled Agent or Tax Attorney…great! But have you thought about “FBAR” and your 2018 tax return!!! You might ask, do I have to worry about this FBAR quagmire if I have never been outside of the United States? YES
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FOREIGN TRUST WITH U.S. JURISDICTION? FRACTIONAL OWNERSHIP OF A FOREIGN ENTITY? BEWARE!!! The Tax Season for filing 2018 tax returns is now upon us and the full brunt of the Tax cuts and Job Act (TCJA) will occupy tax compliance by both the Taxpayers and the Tax Preparers.  One of the most stag

Hello and Welcome to my first News Letter on Matters That Will, Almost Certainly, Affect You in This New Year, 2019.

I know that 2018 was a difficult year and now with the traumatic effect of the U.S. Government Partial Shutdown with the stock markets swings to record lows, we are facing a much higher tax liability for our personal US Tax Returns for 2018.

A lot of deductions we historically were allowed in recent past years have been revised for tax years beginning in 2018 and there is for the most part little that we can do to mitigate the increased tax liabilities. We can, however, calculate our expected tax increase and make a 4th Quarter Estimated Tax Payment by no later than 15th January 2019 for the 2018 tax year. This payment will act to compensate for the unlimite

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If you are considering the New IRS Voluntary Disclosure Program, what questions should you be asking of yourself and your Legal Counsel? On November 20, 2018, the U.S. Internal Revenue Service, (IRS) issued its Memorandum that addresses the process for all domestic and offshore voluntary disclosures
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Lets look at a traditional expensive method of shifting profits from your foreign company to you, the U.S. Shareholder. (Part I)

This is a very recent Tax Court Case, September 2018, where a husband and wife, named Barry and Rochelle Smith, were the grantors of two Domestic Grantor Trusts.  I will use some leeway to fill in areas not noted in the Tax Court Case itself that I believe is more probably than not as we move through this scenario.

Since the totality of this scenario has international entities and transactions, I would assume that the trusts were created outside of the United States, but has fulfilled the conditions of U.S. Treasury Regulations § 301.7701-7 that the trust is a domestic trust if the a court within the United States is able to exercise

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As income tax filing season approaches, the U.S. Commodity Futures Trading Commission (CFTC) is warning investors to be cautious of sales pitches touting “IRS approved” or “IRA approved” virtual currency retirement accounts. BACKGROUND: IRAs are retirement accounts that provide investors wit
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Today, September 4, 2018, t he Internal Revenue Service, IRS, provided a notice that Americans have until September 28, 2018, just over 3 weeks, to apply for the Offshore Voluntary Disclosure Program (OVDP).

I know there are may Americans that have not come forward under one of the many alternatives, which gets fewer and fewer alternative as time moves on. OVDP’s initial launch in 2009 and over 56,000 Americans have used the various terms of the program to comply voluntarily with U.S. tax laws. These individuals with undisclosed offshore accounts have paid a total of $11.1 billion in back taxes, interest and penalties.

The IRS’s end of the OVDP reflects advances in third-party reporting and increased awareness of U.S. individuals of their offshore tax and reporting

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Living abroad can be very exciting, however maintaining your life and finances can become quite complicated. Our global group can help keep you in check. The basic goals are understanding and organizing your financial situation for people who live abroad, hold green cards, maintain dual citizenship,