Category: Tax Planning

FOREIGN TRUST WITH U.S. TRUSTEE?

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 staggering provisions of the TCJA is the situation where your client owns an interest in a foreign entity directly or indirectly through a tiered-entity-structure, (TES).

The above threshold test will certainly raise eyebrows and compel the additional questioning to determine if you or your client falls into this catch-all provision. A simple example of indirect ownership, TES, is as follows:

The above basic schematic shows how e

Calculate Your 2018 Federal Tax Under the New Law

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 high

Traditional Expensive Method of Shifting Profits from Your Foreign Company to You

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

Beware “IRS Approved” Virtual Currency IRAs

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 with certain tax incentives for retirement savings. Earnings grow tax-deferred, which means you won’t pay capital gains taxes if you sell, but gains will be taxed at your normal income tax rate when funds are withdrawn in retirement. There are also penalties for early withdrawal. Some common examples include traditional or tax-deferred IRAs, Roth IRAs, Simplified Employee Pensions (SEPs), or Savings Incentive Match Plan for Employees (SIMPLE) IRAs. All IRAs are held for investors

If You Read This After September 28, 2018, You Are Too Late!!!

The Internal Revenue Service terminated its 2014 Offshore Voluntary Disclosure Program (OVDP) September 28, 2018. “Taxpayers have had several years to come into compliance with U.S. tax laws under this program,” said Acting IRS Commissioner David Kautter. “All along, we have been clear that we

Highly Probably You Will Owe More Tax For 2018

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

Avoid penalty for underpayment of taxes for 2018!

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

IRS Examination Coverage for 2016

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,

Basic of What to Do or Not Do If You Get a Letter from the IRS

If you receive a letter marked from the IRS or the U.S. Treasury, then you are one of millions of individuals who will received the mailing of letters from the U.S. Government and there are many and varied reasons why you may be one of these millions of individuals selected to receive a letter. The suggestions that I am listing below may seem to lack common sense, but I have seen just such happenings that occur when you experience unexpected IRS mailings mixed with the normal stresses of the day.

First, with the IRS envelope in hand, take a deep breath, find a few minutes where you will be able to focus and have a note pad and pen nearby for making notes.

This letter is a personal communication to the addressee. If this letter is not addressed to you, then don’t open it!

Do I need to file a special extension to get an automatic extension to file similar to the IRS form for individual Income Tax Returns…although automatic you still need to file?

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that, to implement the new due date for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), of April 15 (April 18 for 2017), it will automatically grant all taxpayers filing the form a six-month

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