International Taxation In the intricate world of international taxation, one constant remains: the need for accurate reporting and compliance. This is especially true with regard to the W-8 forms, specifically W-8BEN and W-8BEN-E, which are the basis for taxpayers aiming to claim treaty benefits. The recent rise in IRS examination activity makes it crucial to
international tax attorney
FBAR – Foreign Bank Accounts Require Disclosure
FBAR – Foreign Bank Accounts Require Disclosure If you are U.S. Citizen or a Green Card holder and you have a bank account outside the United States, your foreign bank account(s) requires disclosure to the Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) through Form FinCEN 114 or FBAR. Every U.S. Citizen
Breaking Down the Attorney Client Privilege Break Down
Attorney Client Privilege The concept of attorney client privilege as we know it could be shifting in the Ninth Circuit. The 1981 case Upjohn Co. v. United States determined the purpose of attorney client privilege is to “encourage full and frank communication between attorneys and their clients.”1 However, when it comes to legal tax professionals
Internal Revenue Service Form 8938
An Important International Tax Form to Declare Foreign Financial Assets May be filed through the IRS Streamlined Procedures What is it Internal Revenue Form 8938? Form 8938 is used to report specified foreign financial assets when the overall value of the those specified foreign financial assets is over the appropriate reporting thresholds. The form requires
Complying with International Tax Reporting Requirements – Streamlined Procedures May Help
Streamlined Procedures – What Is It and Who Does It Assist? Streamlined Procedures may provide non-tax-compliant US citizens a remedy when the conduct was non-willful. The Streamline includes procedures and terms for filing amended or delinquent returns and for resolving open tax and penalty obligations. Part of the process includes filing three years of income
Do You Own A Foreign Corporation? Have You Filed IRS Form 5471?
What is a Form 5471? IRS form 5471 is a form issued by the Internal Revenue Service (IRS). Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations must be completed and filed by certain taxpayers to report ownership of a foreign corporation. Who Must File Form 5471 and When? There
Own a Foreign Bank Account? Be Prepared to File an FBAR to Avoid Penalties
Foreign Bank Account And Financial Accounts Reporting If you own or are listed as a signer on foreign bank or financial account(s), it must be reported annually if the aggregate balance of the account(s) was equal to or greater than $10,000 USD at any point during the year. Failure to do so may result in
IRS OVDI – Role of the Attorney in the Voluntary Disclosure Process
Role of the Attorney in the Voluntary Disclosure Process An attorney that specializes in taxes can be a great resource to those who are seeking to rectify the non-disclosure status of any foreign accounts and/or income. Although participation in the Voluntary Disclosure program reduces the likelihood that the IRS will pursue further civil and criminal