IRS Streamlined Procedures

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…
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…
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…
Reckless Disregard and Schedule B Reckless Disregard and Schedule B Reckless Disregard and Schedule B: The recent case of US v. Kimble was a court ruling on the issue of Reckless Disregard, Schedule B and Foreign Accounts Compliance. While the case result was not great for Kimble, it is not as bad as some practitioners would like to make it seem for Taxpayers as a whole. In short, the case does not stand for…
Eggshell Tax Audit or Reverse Eggshel Eggshell Tax Audit & Revere Eggshell Eggshell Audit & Reverse Eggshell: Oftentimes, an IRS audit is no big deal at all. IRS Examiners, Agents and Specialists are not attorneys and are (generally) not adversarial. Some even have less tax knowledge than the Tazpayer sitting in the audit. In a common situation, a US taxpayer receives a notice of audit which requires them to respond by correspondence or in person.…
Who Files FBAR for Virtual Currency Offshore Ownership Who Files FBAR for Virtual Currency Offshore Ownership Who Needs to File FBAR for Virtual Currency Offshore Ownership? One of the most complicated types of foreign assets to report to the IRS and FinCEN is virtual currency such as cryptocurrency (Bitcoin, Litecoin, etc.). What makes the reporting of Virtual Currency so difficult is that even though virtual currency has the name “currency” in it  — it is…
International Tax Attorney Chicago  International Tax Attorney Chicago: Our international tax attorney and offshore disclosure team has been very successful in reducing, avoiding and abating offshore penalties for clients statewide. Golding & Golding represents clients in Chicago, with IRS matters involving Voluntary Disclosure and Streamlined Filing Compliance. We have helped numerous clients throughout Chicago with penalties involving Form 3520, 3520-A, 5471, 8621, 8865 and 8938. Even though we are based in Irvine, California, we…
Cryptocurrency John Doe Summons Cryptocurrency John Doe Summons Reveals Crypto Fraud Identities Cryptocurrency John Doe Summons Reveals Taxpayer Fraud Identities: The US Government continues to make cryptocurrency tax and reporting compliance a key enforcement priority. Recently, the District of Massachusetts affirmed the US Government’s request for a John Doe Summons to issue for Circle Internet Financial Inc., or its predecessors, subsidiaries, divisions, and affiliates, including Poloniex LLC (collectively “Circle”). The goal of the summons is…
FBAR Appeals FBAR Appeals FBAR Appeals: When it comes to the FBAR, the IRS does not play fair. Unlike various other tax matters, in which the taxpayer can take their dispute to Tax Court — it is not an option for FBAR Penalties. The reason why, is because the FBAR is not a tax form. When a taxpayer has been penalized as a result of late filing or unfiled FBAR — there is…
FBAR Penalty Appeal FBAR Penalty Appeal FBAR Penalty Appeal: When it comes to the FBAR, the IRS does not play fair. Unlike various other tax matters, in which the taxpayer can take their dispute to Tax Court — it is not an option for FBAR Penalties. The reason why, is because the FBAR is not a tax form. When a taxpayer has been penalized as a result of late filing or unfiled FBAR…