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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 5% Penalty: Do you qualify?

With the standard 2012 Offshore Voluntary Disclosure Penalty at 27.5%, many people in the program and those considering the program, look longingly at the OVDP 5% penalty wondering if it can apply to them. While there still there is a 5% OVDP penalty, its nature has changed so much, this original article is best used to demonstrate the evolution of the IRS OVDI/OVDP...

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%, ...

New IRSMedic Webinar: What to do when your offshore bank is "blacklisted"

We're going to cover what we mean by 'blacklisted' bank, about what your options are, if you can go streamlined, when an opt out in the OVDP makes sense, and about the traps of doing a 'soft' or 'quiet' disclosure.

Another foreign filing requirement: Form BE-10

Every day, at least one US person with business overseas will learn of some horrible US government form they are in non-compliance with. Whether it is a 1040 they didn't report worldwide income on, an FBAR form for foreign bank accounts (or foreign life insurance or pensions), or for an ...

How US taxation of foreign Income works

The rest of the world does not do what the IRS does American exceptionalism is a philosophy that refers to the special character of the United States as a uniquely free nation based on democratic ideals and ...

The 2014 OVDP Pre-clearance: Significant changes

On June 18, 2014, the IRS announced significant (and mostly helpful) changes to all Offshore Voluntary Disclosure Programs (OVDPs). Update February 2017: There have been few pre-clearance changes to speak of since 2014. Once difference is that the IRS says it will start auditing those who filed a pre-clearance and nothing else along with...

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 Opt-out: Offshore Commercial Real Estate Penalty Relief

The Offshore Voluntary Disclosure program assesses a penalty on income-producing real estate on which income has not been reported. To put it another way: suppose you are a US person, you own a flat in London and didn't report ...

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 ...

IRS Expatriation Tax

The IRS Expatriation Tax explained NOTE:  This article is about the exit tax due from US persons, also known as the IRS Expatriation Tax, when they expatriate and relinquish their US citizenship.  For relevant articles about the IRS Expatriation Tax for current US citizens living overseas, see ...

Unreported Foreign Real Estate Income: OVDP/OVDI Options

One recurring concern our clients have is the status of the real estate they may hold overseas—whether a family home or a rental ...

Changes In Overseas Tax Law

Changes In Overseas Tax Law. Anthony Parent, tax resolution lawyer, warns taxpayers that extensive documentation will be required in 2013 if they invest or operate a business overseas, due to changes in overseas tax law. Wallingford, Conn. – July 25, 2012 – Anthony Parent, founder of IRS ...

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