2014

Offshore Enforcement to Remain Top Priority in 2015

Practitioners and students of tax crimes know that most of the commonly charged tax crimes have an element of willfulness which the Supreme Court interpreted in Cheek to mean a voluntary intentional violation of a known legal duty. The reality however, is that some tax crimes do not have an explicit requirement of willfulness but […]

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FBARs and Form 8938

Back in March 2014, I first wrote about FBARshttps://www.mooresrowland.tax/2014/03/dont-forget-those-fbars-aka-fincen-114.html But my recent interaction with clients suggests that I need to revisit the topic. Each U.S. citizen and permanent resident must report worldwide income to the IRS even when paying taxes elsewhere. Moreover, you must file an annual FBAR(now called FinCEN Form 114) disclosing your foreign

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IRS Goes Undercover and the Movement against Corp Tax Avoidance

When it comes up in conversation, I keep telling people one thing – forget FATCA, we are in the midst of a movement that is much bigger than just one law. The drive for international transparency and substance seems unstoppable at this point. It is not just happening at the individual level, it is happening

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Be Careful in Your Choice of Tax Advisors

On September 12th, the Treasury Inspector General for Tax Administration (TIGTA) released its annual report on IRScompliance trends. Individual income tax return examinations conducted by the US Internal Revenue Service decreased in 2013 for the third year in a row, falling to USD1.4 million or one for every 104 tax returns.  Just over 80 per cent were done

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IRS Information Letter on Treatment of Green Card Holders (Noncitizen Lawful Residents) – Release Date: 9/26/2014

The IRS has released this Information Letter 2014-0033, with information about the U.S. tax regime for “green card” holders. The background is that non-citizen resident of the U.S. are subject to U.S. tax.  Key excerpts are: An alien individual is classified as a resident of the United States with respect to any calendar year if he

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American Expats and the Net Investment Income Tax

So a few clients have been asking about the Net Investment Income Tax (NIIT). The purpose of the NIIT is to ensure that individuals with high income levels earned from non-wage sources contribute to the expanded health care program in a similar manner as individuals subject to withholding tax on their wages. In other words,

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Pre-immigration Planning for Singaporeans Moving to the USA

Singaporeans are known for being world travelers.  Many Singaporeans visit the U.S.  Some even decide to temporarily / permanently move to the U.S.  Well known Singaporeans in the states include names like Tila Tequila, Sharon Tay, and Neeraj Khemlani.  Careers in the media aside, one would imagine that Singaporeans decide to temporarily / permanently move

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IRS: Partners’ Share Of LLC Income Is Subject to Self-Employment Tax

So once upon a time, many of us were comfortable thinking that it was possible to have Private equity fund managers take a share of the profits of the partnership as the equity portion of their compensation. The tax rules for compensating service partners created a planning opportunity for managers who receive the industry-standard “two

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