Golding & Golding, A PLC

IRC 965 International Compliance Campaign What is the IRC 965 International Compliance Campaign? IRC 965 International Compliance Campaign: Each year, the IRS introduces several new international enforcement campaigns. The purpose of these campaigns is to put Taxpayers on notice of certain tax issues of which the Internal Revenue Service will prioritize when it comes to enforcement. Back on July 6, 2020, the IRS introduced a new IRC 965 International Compliance Campaign. IRC 965 is the…
Offshore Bank Accounts, Divorce & the IRS Offshore Bank Accounts, Divorce & the IRS Offshore Bank Accounts & Divorce: Many years ago while I was in Law School (which seems like forever-ago), I clerked for a former Chief Judge for Virginia State. He was an incredible attorney, and he taught me one very important tool for the effective practice of law. It’s always ready, aim, fire — not ready, fire aim. More often than not,…
Civil Tax Fraud Penalty Civil Tax Fraud Penalty & the IRS Civil Tax Fraud Penalty: While some tax violations are not necessarily a big deal, IRS Tax Fraud Penalties are tough. With Civil Tax Fraud, the penalties can reach upwards of 75% of the tax liability. In addition, the penalties can lead to even worse penalties, including a potential IRS Special Agent Investigation.   The reason is because in addition to monetary penalties, the stigma…
FBAR for Disregarded Entities FBAR Filing for Disregarded Entities FBAR Filing forDisregard Entities: The IRS does not limit FBAR reporting to individuals. Rather, the U.S. Government requires all U.S. persons (including entities and disregarded entities) to file the FBAR. And, with the Internal Revenue Service taking an aggressive position of matters involving the enforcement foreign accounts compliance, it is important to file the necessary reporting forms, and/or consider amnesty and voluntary disclosure if you…
Reasonable Cause & IRS Penalty Abatement Reasonable Cause & the IRS Reasonable Cause & Abatement of IRS Penalties: When it comes to the IRS and penalties, there are (generally) two situations in which reasonable cause is primarily used. In the first scenario, a person may have already been issued an IRS Penalty, and they are seeking to abate the penalty by proving the mistake was reasonable. In the second scenario, a person realizes they are…
Tax Avoidance vs Tax Evasion Tax Avoidance vs Tax Evasion Tax Evasion vs Tax Avoidance: When it comes to taxes and the IRS, sometimes there is a fine-line between planning to minimize taxes — and committing tax fraud, especially in the realm of international and offshore tax. How a U.S. person determines whether the tax planning activities they are performing is a form of tax planning (which is creative and perfectly legal) or a…
  How does the IRS Find Foreign Accounts IRS Foreign Bank Account Investigations How does IRS Investigate Foreign Bank Accounts? With the IRS‘ increased enforcement of offshore account compliance, trust reporting and income disclosure, U.S. Taxpayers are at higher risk of penalties. The failure to properly report foreign money may result in significant fines. One common question we receive, is How does the IRS Find Foreign Accounts? With the recent creation of several International…
?   FBAR 2020 Explained FBAR 2020: The IRS requirements for submitting the FBAR is not much different than the prior years. This post will serve as a (brief) refresher as to why Foreign Bank Account Reporting should remain on your radar.  The FBAR is the Foreign Bank and Financial Account Reporting Form (aka FinCEN 114). It is not limited to only bank accounts. The form is used to report Foreign Bank Accounts, in addition…
US Tax of Usufruct & Naked Ownership: FBAR & FATCA Usufruct & Naked Ownership US Taxation US Tax of Usufruct & Naked Ownership: Unless you live in Louisiana or are familiar with civil law, you may be unfamiliar with the concept of a usufruct and naked ownership. In many European countries, as well as in Louisiana, there is a form of ownership called naked ownership and Usufruct Law. These types of ownership are different than…
US Taxation of New Zealand Pension Plans US Taxation of New Zealand Pension Plans US Taxation of New Zealand Pension Plans: The pension plan system in New Zealand is similar to many other foreign countries. There is a two/three pillar system, which involves both the state pension, occupational pension, and/or private pension. While New Zealand has a superannuation, the NZ Super operates differently than the Australian superannuation fund. Each year we work with U.S.