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Author Archives: Darlene Hart

IRS Scams Investigations to include Pensions, Insurance & Digital Currency

For about 20 years now, the IRS has been annually publishing a ‘Dirty Dozen’ list of common taxpayer “scams.” The intent is to warn taxpayers, tax professionals, financial institutions, and financial advisors of abusive transactions, including bogus tax avoidance strategies as well as consumer-focused scams that target average taxpayers. The IRS identifies problem areas through audits, promoter […]

ABA Highlights Tax Enforcement Targets

At the American Bar Association (ABA) Conference dated July 7, 2020, The Current State of International Criminal Tax Enforcement, it was announced that the US, Canada, The Netherlands, Australia, and the United Kingdom, (The J5), joined forces in June 2018 in Canada to share operational intelligence, best practices, and coordinate media campaigns and form a […]

US LLC – smart move or poison chalice for foreign persons?

The filing requirements and practical application of a US LLC for foreign owners may force many foreign nationals to reconsider their options.  As of January 1, 2017, Limited Liability Companies (LLCs) formed in the United States, which are treated as disregarded entities and wholly-owned by foreign persons, are subject to new IRS reporting requirements. Such […]

IRS Ramps Up Penalties in 2019

The Internal Revenue Service, which has seen its operating budget slashed over the past eight years, may be looking to increase its use of penalties against those who fail to file documents or pay the taxes they owe on time. The IRS is increasingly making use of its legislative rights to impose penalties on late filing, […]

FATCA: First criminal conviction for failure to comply

We knew it was coming, but this month we now have the first-ever conviction for failing to comply with FATCA.  The US government with help from other countries in what reads like an international James Bond type movie thriller, complete with undercover agents in a sting operation, has shown that they will aggressively pursue those […]

FFI Renewal Deadline Extended to Oct 24, 2017

IRS FATCA Registration FAQ12 provides the following guidelines on the FFI renewal deadline extension. Participating FFIs (including Reporting Model 2 FFIs) that have otherwise complied with the terms of the FFI agreement (including, since January 1, 2017, the current FFI Agreement) have until October 24, 2017, to renew the FFI agreement and continue to be treated as […]

Reflections on 30 Years of US tax abroad

2016 marked the 30 years since I launched US Tax & Financial Services in London. We celebrated this milestone with parties in London and Zurich. It was wonderful catching up with old friends while meeting some new ones too. I have seen a lot of changes since 1986, not only in US tax compliance but in business […]

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