Eli S. Noff, Esq. CPA It is undisputed that U.S. individuals who own foreign companies were treated unfavorably under the Tax Cuts and Jobs Act of 2017 (TCJA) compared to U.S. corporate shareholders. However, an election that allows individuals to treat themselves as corporations can, in the right circumstances, help alleviate the harsh results. Changes […]

Over the past few years, the IRS has increased its attention on offshore bank accounts, earmarking much of its limited budget, staff, and resources towards initiatives such as the Offshore Voluntary Disclosure Program (OVDP) and Swiss Bank Program, and pushing strict compliance of foreign bank and financial account reporting through enforcement measures such as the […]

Eli Noff, Esq., Partner On April 3, 2018, inUnited States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government’s suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof […]

Glen Frost and Eli Noff, partners at Frost and Associates, LLC, recently had the honor of appearing as guest speakers on Financial Consulate’s radio show, Money, Riches & Wealth, hosted by Drew Tignanelli on September 5, 2018. Mr. Frost and Mr. Noff discussed tax issues many listeners face including international tax issues, foreign bank account […]

Eli Noff, Partner On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al.[1]The 5-4 decision discards the antiquated “physical presence rule” — a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation to collect and remit sales taxes. […]

The Internal Revenue Service recently announced a major expansion of its Offer in Compromise program, which is aimed at helping individuals with past-due to taxes to pay off their debts to the IRS. Taxpayers who participate in the program are permitted to settle their tax debts for less than they owe if they are unable […]

Eli S. Noff, Partner Jakarta, Indonesia – 1990 The aroma of my strong Java coffee blended with the smell of the dark teak paneling of the conference room of my client’s office. I glanced at my U.S.-citizen client and then back to the two bankers who had travelled to Indonesia to promote an investment in […]

Leanne Broyles, Esq. What if you could take a portion of your hard-earned wealth, lock it up from your creditors, but keep the key for yourself? It sounds too good to be true, but the Domestic Asset Protection Trust provides a very real and very valuable estate planning tool for achieving this objective. The Domestic […]

Eli S. Noff, Esq., CPA, Partner The objective of the recently expired Offshore Voluntary Disclosure Program (OVDP) enabled willful U.S. taxpayers with undisclosed foreign assets to become compliant with U.S. tax laws, while concurrently avoiding serious statutory civil penalties and practically removing any risk of criminal prosecution. On November 29, 2018, the Internal Revenue Service […]

According to the February 21, 2018, IRS news release, IR-2018-32, there are still circumstances for which interest on home equity loans is still deductible under the Tax Cuts and Jobs Act of 2017. The IRS has now clarified that “taxpayers can often still deduct interest on a home equity loan, home equity line of credit […]