IRS
Can the Streamlined Program or OVDP help Me?
People with unreported foreign assets on tax returns may benefit from the Offshore Voluntary Disclosure Program or the Streamlined process. U.S. persons who own property or other assets in countries outside the United States may do so in part for potential tax advantages. However, taxpayers may still need to report foreign assets on domestic income […]
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New Credit Reporting Agency Standards
By Matthew Tran Effective on July 1st, 2017, the three major credit reporting agencies, TransUnion, Equifax, and Experian, introduced new standards that will require tax liens and civil debts to include more personal information; otherwise, the tax liens and civil debts will be excluded from a person’s credit report. The changes will require tax liens […]
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The Ups and Downs of the Program for Voluntarily Reclassifying Your Workers
Whether a worker is properly classified as an employee or as an independent contractor depends upon the facts and circumstances. Generally, the determination is made under common law tests considering the right to control and direct the individual performing services. However, in some factual situations, the determination of the proper worker classification status may not […]
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Costa Rica Expats May Soon Experience the Benefits of Residency-Based Taxation
Glen E. Frost, Esq., CPA, CFP®; Associate Tax Counsel, American Citizens Abroad For many years, the persistent call for change in the taxation of American corporations and individuals abroad has gone unanswered. However, the current administration’s actions, suggest the very real possibility of new tax rules, sooner rather than later. Indeed, assuming no major legislative […]
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QBI Guidance Issued; Safe Harbor Provided for Real Estate Enterprises
Eli S. Noff, Esq. CPA, Partner As we detailed in Section 199A: New 20% Pass-Through Deduction1, the Tax Cuts and Jobs Act of 2017 created new Internal Revenue Code §199A-providing a significant tax break to flow-through entities and structures. Subject to certain limitations, many eligible taxpayers (excluding C corporations) may deduct up to 20% of […]
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Form 4340 is Sufficient Corroborating Evidence Proving Issuance of Notice of Deficiency
Eli S. Noff, Esq. CPA, Partner On January 28, 2018, the court in U.S. v. Meyer,1considered a challenge to the proper mailing of Notices of Deficiency for two tax years and found Form 4340 sufficient as corroborating evidence for both years. Background A deficiency assessment results from the Internal Revenue Service’s (IRS) finding that a […]
Audit of the Offshore Voluntary Disclosure Program
The Treasury Inspector General for Tax Administration (“TIGTA”) completed an audit of the Offshore Voluntary Disclosure Program (“OVDP”). US citizens are taxed on their worldwide income and must report bank accounts when their aggregate balance exceeds $10,000. The OVDP and other similar programs allow taxpayers a mechanism to come forward and get into compliance with […]
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Credit Suisse Hearings focus attention on Foreign Bank Accounts
The chief executive of Credit Suisse recently appeared in front of a Senate subcommittee to answer questions related to the bank’s role in aiding tax evasion. A similar hearing in 2008 resulted in a $780 million fine for Swiss bank UBS after the bank admitted helping U.S. taxpayers shield assets to avoid taxes. In conjunction […]
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The Foreign Account Tax Compliance Act: What is FATCA?
Eli S. Noff, Esq.,CPA, PartnerBrent Conrad In an effort to reduce persistent high unemployment rates resulting from the 2008 financial crisis, President Obama signed The Hiring Incentives to Restore Employment Act of 2010 (HIRE Act)1to incentivize employers to hire and retain workers. Tax incentives provided in the HIRE Act included: (1) a payroll tax holiday, […]
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Innocent Spouse Relief (IRC §6015)
Eli S. Noff, Esq., CPA, Partner Under Internal Revenue Code (IRC) §6013(d)(3), spouses who file joint income tax returns are subject to joint and several liability for the income tax reported on those returns. In other words, the IRS will hold each spouse responsible for the entire amount of tax due. Sometimes, however, one spouse […]
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