IRS Streamlined Procedures

Cryptocurrency Tax Lawyer Cryptocurrency Tax Lawyer Cryptocurrency Tax Lawyer: Over the past decade, cryptocurrency has expanded exponentially from its early days on the dark web. These days, cryptocurrency is used, exchanged and sold on many platforms. Whether for investment purposes, wages or used as currency (even though technically the IRS does not categorize it as currency), cryptocurrency is here to stay. At the current time, U.S. tax laws involving cryptocurrency are still in flux. Even…
Texas Court Rejects FBAR Non-Willful Per Account Penalty Texas Court Denies FBAR Per Account Non-Willful Penalty Texas Court Rejects FBAR Non-Willful Per Account Penalty: This case involves Alexandru Bittner and Non-Willful FBAR Penalties. We have authored several legal articles on this case, as it is a very controversial FBAR Penalty, in which the IRS issued $3M in non-willful FBAR penalties. But, in a recent 2020 case ruling, the District Court in Texas (Eastern…
PFIC (What is a Passive Foreign Investment Company) What is a PFIC (Passive Foreign Investment Company) What is a PFIC?: 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…
Form 5471 Who Must File & Report a Foreign Corporation to IRS Form 5471  Form 5471 : Form 5471 is used to report foreign corporations to the IRS. Technically, the form is referred to as the Information Return of U.S. Persons With Respect to Certain Foreign Corporations.  The Form is generally due to be filed by U.S. taxpayers at the time their tax return is due. Even if a person is not required to…
Form 3520 Form 3520  Form 3520 & Instructions: The IRS Form 3520 (2020) is used to report a foreign gift, inheritance or trust distribution from a foreign person to the IRS. It does not have to be a “Foreign Gift.” Rather, if a foreign person gifts U.S. property – there may be a Form 3520 reporting requirement as well.  The Form 3520 complexity is on a sliding scale. On one end of the spectrum, reporting…
Form 8840: Closer Connection Exception to Substantial Presence Form 8840 Form 8840: The Form 8840 is an International Tax Form that 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…
FBAR Filing Requirements FBAR Filing Requirements FBAR Filing Requirements: The FBAR (Foreign Bank and Financial Account Form) aka FinCEN Form 114 is an international information reporting form. And, depending on when you are reading this, you may still have time to timely file your FBAR in the currnet year. The FBAR deadline used to be June 30th. Then, the FBAR due date was changed to April. But, to provide help to U.S. Persons just learning about…
Legal Resident vs Tax Resident Legal Resident or Tax Resident in the US Legal Resident or Tax Resident: When it comes to U.S. Tax, the term resident can be very complicated. For example, a U.S. person may be a U.S. Citizen or Legal Permanent Resident — and they will automatically be subject to U.S. tax on their worldwide income. But, a person may not be a legal resident (because they are a foreign national who…
6013(g) Election & Foreign Spouse 6013(g) Election 6013(g) Election for Foreign Spouses: While the IRS requires U.S. Persons to report their worldwide income, assets and accounts on their annual tax return, the same is not required for Foreign Spouses. If a Foreign Spouse does not have any U.S. Income, then under most circumstances, they would not have any tax return requirement. But, if a U.S. Person has a foreign spouse, they may wish to include…
6013(g) Foreign Spouse Election for U.S. Tax 6013(g) Election 6013(g) Election for Foreign Spouses: While the IRS requires U.S. Persons to report their worldwide income, assets and accounts on their annual tax return, the same is not required for Foreign Spouses. If a Foreign Spouse does not have any U.S. Income, then under most circumstances, they would not have any tax return requirement. But, if a U.S. Person has a foreign spouse, they may wish…