IRS Streamlined Procedures

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…
FATCA & Bitcoin: What are the Filing Requirements FATCA & Bitcoin: What are the Filing Requirements FATCA and Bitcoin Reporting: Over the past few years the, U.S. government (and IRS specifically) has strictly enforced cryptocurrency reporting and tax related compliance. This is especially true when the Bitcoin is located abroad. When it comes to FATCA reporting of Bitcoin, it is more complex than FBAR reporting. That is because whether or not Bitcoin is in a…
Cryptocurrency FBAR Reporting Cryptocurrency FBAR Reporting Cryptocurrency FBAR: When it comes to rules involving IRS reporting of offshore accounts, the reporting a virtual currency such as cryptocurrency, is complicated. That is because the U.S. government has not provided a bright-line test to determine what is considered a foreign account for FBAR Reporting.  While the U.S. Government has provided some insight as to what is reportable, they have not provided a concrete definition that taxpayers can…
Income Tax Treaty and Double Taxation Agreements What is an IRS Tax Treaty? Income Tax Treaty: IRS Double Taxation Agreements When it comes to international tax, tax treaty law is complex. That is primarily because most tax treaties are many pages long and contain voluminous amounts of information and IRS analyses, which is both  dense and complicated. That is not to say it takes an International Tax Law Specialist to understand how and apply principles…
Closer Connection Exception to IRS Substantial Presence Closer Connection Exception to Substantial Presence Closer Connection to the Substantial Presence Test: When a foreign person resides in United States, they risk becoming subject to US tax on their worldwide income as a “U.S. Person.” Generally, individuals who may become subject to U.S. tax as a U.S. Person are limited to U.S. citizens and Legal Permanent Residents. But, there is a third category of individual who may…
Domestic Voluntary Disclosure IRS Domestic Voluntary Disclosure & the IRS  Domestic Voluntary Disclosure IRS: When a Taxpayer makes a voluntary disclosure to the IRS, the offshore aspect of the submission is the one aspect most people are familiar with. In a very common scenario, a U.S. person will have unreported foreign accounts, assets, investments, and/or income which was not previously reported to the U.S. government. But, the domestic voluntary disclosure program can be equally…
Is Tax Evasion a Felony? Why Is Tax Evasion a Felony? Is Tax Evasion a Felony? When a person believes they may have committed a serious tax violation, one of the most common researched terms on the internet is “tax evasion” and whether it is a criminal offense. Tax evasion is a criminal offense, and it is one of the tax crimes that the IRS and U.S. government in general seeks to enforce against Taxpayers. …
Foreign Earned Income Exclusion Foreign Earned Income Exclusion Foreign Earned Income Exclusion: When a U.S. person works overseas and meets the necessary IRS requirements, they may be able to exclude a portion of their foreign income and housing from their US taxes. There are very specific requirements in order to take advantage of this role. One common misconception is that if a person qualifies, then they do not have to include the income on their…
Foreign Rental Income & Depreciation Foreign Rental Income & Property Depreciation Foreign Rental Income & Depreciation Rules for US Tax: The United States is one of the few countries that taxes U.S. Persons on their worldwide income. Therefore, when a U.S. Person has foreign rental income from a property outside of the United States, that income is taxable and reportable on a US tax return. Specifically, foreign rental income and depreciation is included on IRS
FATCA India Compliance FATCA India Compliance Are Indian Accounts, Assets & Income Reportable in the U.S.?: There are many complexities involving Indian accounts, assets & income. The interplay between Indian Money and the U.S. tax system and IRS offshore compliance has many components to it. That is because many of the tax rules in India are different than the rules in the United States. In general, the tax rules on passive assets and interest are…