Golding & Golding, A PLC

FBAR Late Filing Penalty and How to Submit Delinquent Forms FBAR Late Filing Penalty and How to Submit Delinquent Forms: The FBAR Late Filing Penalty originates from the failure to timely report offshore accounts, assets, and investments on the FBAR (aka FinCEN Form 114). The form is due to be filed at the same time your tax filing is due. The failure to file a timely FBAR may result in significant fines and offshore penalties
Taxes & H-1B Visa: IRS Tax Return Rules for U.S.Residents Taxes & H-1B Visa: IRS Tax Return Rules for U.S.Residents The IRS Tax Return Rules for U.S.Residents are complex, and the IRS is in full enforcement mode. Generally, U.S. income tax and offshore reporting refers to legal permanent residents (Green card holders) and U.S. citizens. But, there is a another group of individual U.S. Persons who may become subject to U.S. tax and offshore reporting…
FBAR Foreign Life Insurance Policy Reporting FBAR Foreign Life Insurance Policy Reporting: The FBAR Foreign Life Insurance Policy Reporting IRS rules are complex. Even though most owners of a foreign life insurance policy overseas do not consider their own insurance policy as a foreign account, the IRS does. (of course they do, right?) Technically, the policy will have an identifier, which is then reported as an account number on the FBAR (FinCEN Form 114).…
Offshore Accounts, The IRS & Your (Fact vs. Fiction) Offshore Accounts, IRS & You: Separating Fact From Fiction: Reporting Offshore Accounts to the IRS is complex. Each year we are contacted by thousands of clients about offshore accounts, assets, investments, and income. While we haven’t seen it all…we have seen a lot. And, as it comes time to prepare your streamlined filing application (domestic or foreign), you may begin to have some…
PFIC (What is a Passive Foreign Investment Company) What is a PFIC? (Passive Foreign Investment Company): A PFIC is a Passive Foreign Investment Company.  When it comes to international tax, the IRS PFIC (Passive Foreign Investment Company) is one of the most complex and challenging areas of tax law. In fact, most CPAs want nothing to do with PFIC, which is why oftentimes our team is retained to handle both the legal analysis and tax…
IRS Seeks Court Judgment for Multiple FBAR Non-Willful Penalties IRS Seeks Court Judgment for Multiple FBAR Non-Willful Penalties: The IRS Seeks Court Judgment for Multiple FBAR Non-Willful Penalties in the case of U.S. vs. Bittner. Why? Because during the Foreign Bank Account Reporting period at issue, Taxpayer had 50+ accounts and suspect facts surrounding the non-reporting. The analysis of the case is complex and is being misused by other attorneys to scare taxpayers. And, with the…
Form 8840 (2020) – Closer Connection Exception Statement for Aliens. Form 8840 (Closer Connection Exception Statement): Form 8840 is used as an IRS exception to the substantial presence test. When a person is neither a U.S. citizen nor legal permanent resident, they are typically not subject to tax and reporting on their worldwide income — because they are not a U.S. Person. But, when a person meets the substantial presence test they may…
OVDP Lawyers (Important Questions to Ask Counsel Before Hiring) OVDP Lawyers: The term OVDP Lawyers is a catchall phrase used to describe a tax attorney specialist who represents clients in the different IRS Offshore Voluntary Disclosure programs. This includes traditional domestic and offshore Voluntary Disclosure (VDP), Streamlined Filing Compliance Procedures – both domestic and foreignDelinquency Procedures, and Reasonable Cause. With the IRS taking an aggressive position on matters involving foreign
Reporting Foreign Gifts or Inheritance to the IRS (3520, FBAR & FATCA) Reporting Gifts From a Foreign Person to IRS: Reporting Gifts From a Foreign Person to IRS (more accurately, the failure to do so) is big business for the IRS. When a U.S. person receives a gift from a foreign person (including inheritance), the U.S. person may have an offshore reporting requirement on Form 3520. In addition, depending on the type and nature…
Inheriting Foreign Accounts & Offshore Assets Inheriting Foreign Accounts: Offshore Assets, FBAR & FATCA 8938:  The Inheriting Foreign Accounts rules are hard. In addition, offshore asset filing and disclosure requirements are complex. If a U.S. person inherited Foreign Accounts or Overseas Assets, they have various FBAR Filing and Form 8938 foreign asset reporting requirements. These are disclosed on various international reporting forms. The most important foreign account requirement is generally the FBAR. The…