December 10, 2018

IRS Examination Coverage

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 … [Read more...]

Foreign Bank Account Report due June 30, 2016

This alert serves as a reminder that you may need to file a Report of Foreign Bank and Financial Accounts with respect to your foreign assets. For calendar year 2015, an FBAR is required to be filed on or before June 30, 2016. The FBAR form is now called FinCen Report 114, and superseded the Form TD … [Read more...]

End of the year gifting

Hello to you as this Holiday Season is now upon us with such energy and joy of families being together after a long year. I wish you a safe and happy Holiday and a great New Year. As a tax attorney, I just can't stop thinking of last minute tips that may help you and me for April's filings. … [Read more...]

Mandatory Filing for U.S. Persons with Interests in Foreign Business Enterprises

A new change in reporting requirements imposes a non-tax filing obligation on “U.S. Reporters” with interests outside the U.S.  The BE-10 report is one of several surveys used by the U.S. Bureau of Economic Analysis (BEA) to collect information about inbound and outbound foreign investment under the … [Read more...]

Unextendable deadline of June 30, 2015 FBAR

Deadline Notice: The Foreign Account Tax Compliance Act (FATCA) filing deadline for the Report of Foreign Bank and Financial Accounts, known as the (FBAR) is still June 30, 2015, but now has expanded its application to individuals. However this time it is different! New individuals and entities … [Read more...]

Is there a DING knocking at your client’s door?

  In 2013 the Internal Revenue Service (“Service”) issued several private letter rulings (“PLRs”) sanctioning the use of a state income tax planning strategy known as the Delaware Incomplete Non-Grantor trust—or the “DING” trust. DING trusts are designed to lower the state income tax burden … [Read more...]

IRS: Supports Legitimate Captives but Warns Against Captives Lacking Substance

The Internal Revenue Service (“the Service”) annually publishes its Dirty Dozen list.  The Dirty Dozen list compiles a variety of scams along with a list of transactions that have the potential for tax abuse.  The purpose of the Dirty Dozen list is to remind taxpayers to protect themselves against a … [Read more...]

Is it Time to Form Your Own Insurance Company?

Regardless of the business you run, there is risk. And the universe of risks applicable to your circumstance will differ (often wildly) from other businesses. Even businesses in the same industry can present very different risk profiles. The universe of risk applicable to your business breaks … [Read more...]

DOJ Offers Swiss Banks a Deal

In 2013, The Justice Department (DOJ) announced a program that is designed to encourage Swiss banks to cooperate in their ongoing investigations of the use of foreign bank accounts to commit tax evasion. DOJ also released a joint statement with the Swiss Federal Department of Finance, stating that … [Read more...]

IRS Starts Scrutinizing the Insurance Industry with Swiss Partners

In accordance with the DOJ Swiss Banking deal, Swisspartners, a group of Swiss asset management and life insurance companies (which, among its other insurance products, provided customized private placement life insurance polices to US persons) agreed to resolve a US criminal tax investigation. … [Read more...]