2017

Bye Bye John…but what about amnesty programs?

U.S. Tax Planning /

As expected, IRS Commissioner John Andrew Koskinen will step down in November.  It is expected that this may have implications for 2 key offshore voluntary compliance programs that we cover for many of our international clients. These are – 1. The streamlined initiative and 2. The OVDP http://www.derrenjoseph.com/2015/02/streamlined-foreign-offshore-procedures.html Note: The above reference link was live on […]

Bye Bye John…but what about amnesty programs? Read More »

Tax Court Declines to Follow Rev. Rul. 91-32 – Important Development for Foreign Investors!

Tax Planning for U.S. Real Estate Investing, U.S. Tax Planning /

On July 13, 2017, the U.S. Tax Court (Tax Court) issued a 55-page opinion rejecting the long-standing position of the Internal Revenue Service (IRS) as outlined in Revenue Ruling 91-321 concerning the sale by a foreign person of an interest in a partnership that is engaged in a U.S. trade or business for U.S. federal

Tax Court Declines to Follow Rev. Rul. 91-32 – Important Development for Foreign Investors! Read More »

New Sales Tax Amnesty Program For Online Sellers – August to October 2017

U.S. Tax Planning /

According to their website, “the Multistate Tax Commission (MTC) is an intergovernmental state tax agency working on behalf of states and taxpayers to facilitate the equitable and efficient administration of state tax laws.” In this case, the MTC’s Amazon FBA Sales Tax Amnesty is designed to help Amazon FBA sellers become sales tax compliant, but

New Sales Tax Amnesty Program For Online Sellers – August to October 2017 Read More »

FinCEN Targets Shell Companies Purchasing Luxury Properties in Seven Major Metropolitan Areas

Online Selling, Tax Planning for U.S. Real Estate Investing, U.S. Tax Planning /

The situation in the info-graphic above was the situation in January 2017.  Now in August 2017, the net has been cast wider.  See release below… http://FinCEN Targets Shell Companies Purchasing Luxury Properties in Seven Major Metropolitan Areas Contact: Steve Hudak 703-905-3770 Immediate Release August 22, 2017 WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced the issuance

FinCEN Targets Shell Companies Purchasing Luxury Properties in Seven Major Metropolitan Areas Read More »

Another Plea Agreement for failing to declare an Offshore Account

FBARs and Banking /

If you have not already done so, please read this primer on FBARs before continuing –  http://www.derrenjoseph.com/2014/11/fbars-and-form-8938.html So often, we are asked whether the authorities come after taxpayers who failed to disclose 6 figure accounts?   Or whether the focus is only on taxpayers who fail to disclose 7 figures and above.   Here’s an

Another Plea Agreement for failing to declare an Offshore Account Read More »