Category: Tax Planning

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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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With nearly 10 million U.S. taxpayers facing a penalty for underpayment of estimated tax last year, you should plan ahead, understand the options and avoid the huge penalty when filing 2018 Tax Return! And time is moving so quickly you may already be in the unfortunate penalty provisions.

Those of us who fall into the following categories are very susceptible to these penalties:

1. Self-employed 2. Receiving other income, such as a. Interest, b. Dividends, c. Self-employment, d. Capital gains, e. Prizes and awards or f. Too little tax withheld from wages. You probably need to either: 1. Immediately begin making Estimate Tax Payment, 2. Immediately make a Lump Sum Tax Payment for 2018 3. Increase your withholding on Earnings 4. Increase withholding on Royalties, Capital Gai

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Is it possible at this late date? The new tax act of the Trump Administration, The Tax Cuts and Jobs Act, made significant changes for individuals, but the biggest were the loss of Itemized Deductions for high tax States, like California and New York, where Sales Tax, Real Estate Tax, State Income T
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The Internal Revenue Service has listed the percentage of tax returns filed and examined by the amount of Adjusted Gross Income, see below. The returns showing Adjusted Gross Income, AGI, for 2016 of $10,000,000 or more were the highest audit at 14.52%. The returns with AGI of $75,000 to under $100,000 were the lowest audited returns for tax year 2016.

The IRS can audit your tax returns for returns filed up to 3 years from the date of the returns being filed. So, if you filed your 2016 tax return with an extension from April 15, 2017 to October 15, 2017, then the IRS has 3 years from October 15, 2017 to examine your 2016 tax return. This means the IRS can send you an audit notification letter up to October 15, 2020. So, be sure to keep all of your receipts, checks, bank statement

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The IRS has announced that its Offshore Voluntary Disclosure Program (OVDP) will end on 28 September 2018.  US citizens are subject to US tax on worldwide income even if they are not resident in the US.

A failure to comply may result in civil and criminal penalties being imposed.  The OVDP enables US expatriates to voluntarily resolve past non-compliance with reduced penalties and interest for voluntary disclosure.

A voluntary disclosure will not automatically guarantee immunity from prosecution – however, in practice a voluntary disclosure usually results in the IRS recommending no prosecution.

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One wonders whether it is beneficial to remain out of the U.S. Tax Return filing compliance system or seriously consider being in compliance with U.S. laws on filing a U.S. Tax Return. Of course, one of the best methods in making this determination is to seek experienced and wise counsel to assist a