Golding & Golding, A PLC

Who is a Nonresident Alien for US Tax? Who is a Nonresident Alien for US Tax? Nonresident Alien (NRA) vs Resident Alien: Unlike a Resident Alien, a Nonresident Alien is treated much differently by the IRS for US tax purposes. Generally, a Nonresident Alien has no US tax filing or reporting requirement, unless they proactively make themselves subject to US tax — either by acquiring US assets or generating US income. Oftentimes, due to…
Houston Tax Attorney Indictment Involving Overseas Tax Fraud Houston Tax Attorney Indictment Involving Overseas Tax Fraud Houston Tax Attorney Indictment for Tax Fraud using Offshore Entities: In recent years, The US government has significantly increased enforcement of tax fraud related matters — especially when offshore entities and disclosure is involved – and tax attorneys are not immune for the DOJ. Recently, in April of 2021 a tax attorney based out of Houston, TX was indicted…
Puerto Rico Act 60 Taxpayer Audits for High Net Worth IRC 937 & Puerto Rico Act 60 IRS Audit Compliance High Net Worth Taxpayers & Puerto Rico Act 60 Tax Audits: Act 60 Has been in the news recently for many reasons. First, some members of Congress have determined that they want to make Act 60 (which includes previous Acts 20 and 22) a key enforcement compliance priority. In addition, a few months back the…
Form 3520-A Foreign Trust Filing & Reporting Requirements Form 3520-A Foreign Trust Filing & Reporting Form 3520-A Foreign Trust Filing & Reporting: When it comes to international tax and offshore tax compliance for US Persons, it does not get much more complicated than foreign trusts and Form 3520-A (Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)). Whether it is a grantor trust, non-grantor trust, or an unintentional trust such…
Foreign Trust Form 3520-A Filing Requirements & Reporting Form 3520-A Foreign Trust Filing Requirements What are the Form 3520-A Foreign Trust Filing Requirements: When it comes to international tax and offshore tax compliance for US Persons, it doesn’t get much more complicated than foreign trusts and Form 3520-A (Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)). Whether it is a grantor trust, non-grantor trust, or an unintentional trust such…
FBAR Instructions FBAR Instructions FBAR Instructions: The IRS and FinCEN instructions for filing the FBAR can be confusing. It is required to be filed by US Persons, but US persons includes individuals, trusts, entities and more. We have worked with thousands of clients on matters involving the FBAR, so we wanted to throw our hat in the ring and give you our version of the FBAR instructions, and a guide to 25 important Foreign…
Cryptocurrency Tax FAQ Cryptocurrency Tax FAQ Cryptocurrency Tax FAQ: Cryptocurrency tax enforcement has become a key compliance priority for the IRS. While the tax rules continue to evolve, the past few years have proven that the Internal Revenue Service seeks to aggressively seek enforcement. In 2019, the IRS issued a revenue ruling (RR 2019-24) on the treatment of crypto. Despite the revenue ruling, many questions remain unanswered about how crypto income and reporting is treated…
Roth IRA for Covered Expatriates Roth IRA for Expatriates Roth IRA for Expatriates: When it to expatriation, one of the biggest concerns for U.S. Citizens and Lawful Long-Term Lawful Permanent Residents (Long-Term Residents) is what happens to their tax deferred/tax exempt assets and investments in the United states. If the expatriate is considered a Covered Expatriate, then they have to do a deep-dive into their financial world to determine if they…