International Tax Planning

International Tax Planning: Transferring Funds Between Countries

If you are a lawful permanent resident or citizen of the United States with loved ones in another country, you may need, at some point, to transfer money to or receive money from them. If the transfer is for a significant amount, whether all at once… Read More
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Categories: Tax Law
Modify Irrevocable Trust

Can I Modify My Irrevocable Trust?

There are a number of reasons people create irrevocable trusts, including the desire to remove wealth or property from their estate for tax planning purposes or to protect assets. As the name suggests, irrevocable trusts cannot be revoked. But can th… Read More
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Categories: Estate Planning
Business Formation

Business Entity Planning for Asset Protection and Tax Considerations

When starting a new business, there are literally hundreds of decisions to be made. One of the first, and most important, is the type of entity under which the business will operate. Whether your business employs only you, or a hundred other people,… Read More
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Trust Fund Recovery Tax

Trust Funds and Tax Liability

Employers, as a matter of course, withhold employment taxes (including Social Security taxes) and income taxes from employees’ pay. These withheld funds are held in trust until the person responsible for paying them makes a federal tax deposit… Read More
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Categories: Tax Law
Court Ruling

Non-Willful Failure to File FBAR: Moore v. United States

U.S. taxpayers seeking to resolve a foreign bank account reporting (FBAR) issue using the IRS’ streamlined procedures must certify, under penalty of perjury, that any failure to report income or accounts or pay taxes as required was “non-will… Read More
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Categories: Tax Law
Good and Bad

Changes to FBAR and OVDP Law: the Good, the Bad, and the Costly

If you have signature authority over a foreign financial account, or any financial interest in such an account, you may be required by the Bank Secrecy Act to file a report (FBAR) with the U.S. Department of Treasury if those accounts exceed certain… Read More
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Categories: Tax Law
Statute of Limitations

Streamlined Filings and Statutes of Limitation

Regular readers of this blog may remember an earlier post discussing foreign bank and financial account reporting requirements (FBAR). That article discussed two voluntary disclosure programs, the Offshore Voluntary Disclosure Program (OVDP) and the… Read More
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Categories: Tax Law
Taxation of Stock Options

Understanding the Taxation of Stock Options

If you receive stock options as part of your employee compensation package, your company may have provided you with some general tax advice. However, most people require more extensive guidance in order to avoid the tax pitfalls, and seize the tax ad… Read More
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Categories: Tax Law
Irrevocable Life Insurance Trust

Benefits of an Irrevocable Life Insurance Trust

Most American adults are aware that they should have life insurance, particularly if they have minor children or other dependents. Life insurance does provide a large measure of security for families. However, people often fail to consider the fact t… Read More
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Categories: Estate Planning
IRS Offer in Compromise

IRS Offer in Compromise

Some U.S. taxpayers may have a tax liability they are simply unable to pay, a tax debt for which there is doubt as to liability, or a tax debt for which payment would cause a severe economic hardship. When this happens, the Internal Revenue Service (… Read More
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Categories: Tax Law

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