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What Foreign Investors in U.S. Real Estate need to know

IRS Form 5472 is now required for Foreign-owned Limited Liability Companies (LLCs), which include LLCs that own US real estate. The penalty for not filing a form 5472 is ...

OVDP for your foreign corporation or other entity?

The IRS Offshore Voluntary Disclosure Program (OVDP) is not just for individuals. Thanks to a harsh and extensive international tax form penalty regime, there can be a great incentive to enter into an offshore program to cure any of these unfiled or substantially incomplete forms:

What to do about a frozen Swiss and other bank accounts

Certain financial institutions --- not just in Switzerland --- are threatening and actually freezing bank accounts for lack of US tax and bank reporting compliance. In this article, we will explain why bank accounts are usually frozen and the action you may be able to take to regain access to your funds once again. 

Streamlined Foreign Offshore Eligibility

The liberalized 2014 Streamlined Foreign Offshore Process eligibility were on June 18, 2014 and remain in effect as of this writing.  There are many benefits to this disclosure program, mainly a 0% offshore penalty by default. In this article, we outline the steps to determine if you are eligible, and the procedure to complete a successful streamlined...

Was your IRS Offshore Voluntary Disclosure submission declined?

If you have made what you thought was a timely and complete Pre-Clearance or Offshore Voluntary Disclosure Program (OVDP) submission, you may be wondering why you were denied or rejected. The good news is there are alternatives available to...

IRS IPU: Is your Corporation a Controlled Foreign Corporation (CFC)?

The reason CFC or non-CFC the status is so important is because once a CFC determination is made, this triggers the possibility of the dreaded "Subpart F income"...

Understanding the IRS OVDP Offshore Penalty

The current 2012 Offshore Voluntary Disclosure Program presents taxpayers faced with a potentially high IRS offshore penalty (up to 50% of foreign account value per year, for unfiled FBARs) the chance to disclose their foreign assets voluntarily and accept an IRS Offshore Penalty of 27.5%, ...

OVDP for US Corporations, Partnerships and Trusts

We can start with the bad news. Only US individuals and US estates qualify for the Offshore Streamlined Disclosure Program. So what should you do if you have an interest in a C - ...

2015 IRS tax filing deadlines for Foreign Income and Expats

IRS Foreign Income Tax Returns: Important 2015 Deadlines Last week, I wrote an article about the 2015 tax filing deadlines for domestic filers. As promised, here is the 2015 tax filing deadlines for foreign individual filers. I think you will see why it took me some time to draft ...

Steamlined Compliance Procedures FAQs for Domestic Cases

On October 8, 2014, the IRS published "Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States Frequently Asked Questions and Answers." The IRS updated these FAQs on September 29, 2016, bring the total of questions to 17.

2014 OVDP Rule Changes Have Been Announced

These are the highlights we see so far from the just released 2014 OVDP FAQ: 50% offshore penalty for those whose bank is under investigation and submit a disclosure after June 30 2014, Streamlined domestic program for those who can certify non - wilfulness can opt for ...

What does the IRS "Standard" OVDP process?

NOTE: This article was written on February 2, 2014 IRS OVDP  process rules have changed substantially as announced by the IRS on June 18, 2014. This information presented below should be viewed with care. While there is no substitute for legal ...

OVDP Costs: 2014 IRSMedic OVDP Guide - Part 3

In Part 3 of the 2014 Offshore Voluntary Disclosure Guide, Tax Attorney Anthony E. Parent discusses the OVDP costs of complying with the various Offshore Programs, including attorney fees, along with some of the risks associated with not disclosing foreign offshore bank accounts to the IRS.

OVDP FAQs 12-21: 2014 IRSMedic OVDP Guide - Part 2

In Part 2 of the 2014 IRSMedic Offshore Voluntary Disclosure Guide, tax attorney Anthony Parent discusses the OVDP process considerations and more specifically, the IRS OVDP FAQs #12-21.

OVDP FAQ 29: Think Before You Leap

It's no secret that many US persons who have been intentionally hiding income from the IRS have used shell companies, such as foreign corporations, trusts and partnerships. I claim no clairvoyance on the possibility of avoiding detection, but I've been told by people within the IRS that the IRS suspects that the vast majority of people who haven't come clean with unreported accounts and income are hoping that their use of these foreign shell companies will protect them from detection.

What is a Form 5472 and when it is required to be filed?

IRS Form 5472 fulfills the reporting requirements outlined in Title 26 United States Code, Sections 6038A and 6038C, and it is used for the reporting foreign corporation to disclose information about certain reportable transactions that occur with foreign or domestic related parties.

Offshore Voluntary Disclosure: Not Just The FBAR

When we blog about offshore voluntary disclosure issues, we typically focus on the FBAR form, because that is the form that has affected the most people. There are a LOT of people who did not file that form simply because they didn’t know about it. But, there are other forms that you also need to ...

IRS Letter 906: What Are The Options?

At the end of the OVDP process the assigned agent sends out a closing agreement, IRS Letter 906, also called Form 906. It summarizes the Offshore FBAR-equivalent penalty being assessed and asks that the taxpayer sign off on the agreement and send payment (although a standard IRS collection alternative can be arranged ...

Foreign Interest Reporting Forms: File To Avoid Steep Penalties

We have written a lot in the past about the FBAR - -   Report of Foreign Bank Accounts, the form on which you annually report any foreign bank or financial accounts if you had more than $10,000 during that year. There is a lot of focus on the FBAR, but in fact, that is not the only foreign ...

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