While there has been no official change to the current FBAR penalty rules we laid out in 2015, it should be noted there was a recent court case which has reached an unfavorable result for taxpayers with regard to potential FBAR non-willful penalties. In an April 2019 California District Court case (U.S. vs Boyd), the […]

The US tax year ends on 31 December 2019. As always, the final months of the year provide an opportunity to focus on 2019 year-end tax planning opportunities available to optimize US tax for the 2019 tax year. Effective year-end tax planning starts with understanding both current circumstances and subsequent year issues that may affect a […]

NOTE: The IRS has extended the filing deadline for this year.  Please read COVID-19 IRS update: US tax filing deadline extension. Below are the 2020 US tax deadlines for the 2019 tax year. January 15, 2020 Deadline for Individuals to pay Quarter 4 of their 2019 Estimated Income Tax payment. If you have income that does […]

Please note, the IRS released an early draft Form 1040 for the 2019 tax year which contains a new item – 2019 Form 1040, Schedule 1, Additional Income and Adjustments to Income. The checkbox at the top of Schedule 1 asks taxpayers about their interests in virtual currency. Specifically, it states, “At any time during 2019, […]

On September 6, 2019, the Internal Revenue Service (IRS) announced a new procedure that allows certain non-compliant US citizens who relinquished their US citizenship to become US tax compliant. This procedure is geared towards ‘Accidental Americans’ who were unaware of their US tax obligations. Under this procedure, no US social security number is required. The […]

In 2017, Large Business and International (LB&I), the division of the IRS which serves corporations, subchapter S corporations, and partnerships with assets greater than $10 million, announced the identification of 13 initial campaigns, some of which are directed primarily at international tax issues concerning individuals with offshore contacts. The launch of such campaigns is the […]

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 […]