Introduction to the FBAR Penalty Dispute: In a significant decision, the U.S. Supreme Court recently ruled the penalty for violating the “Report of Foreign Bank and Financial Accounts” (FBAR) rules applies on a per-report basis, rather than a per-account basis. This decision brings clarity to a previously divided area of law, as the Fifth Circuit
international tax attorney san diego
Tax Treaty Provisions Are an Important Part of International Tax Reporting File IRS Form 8833 to Avoid Penalties!
What is a Tax Treaty? A tax treaty is an agreement between two countries intended to address and resolve issues such as double taxation of income for each country’s citizens or residents. The United States has tax treaties in place with numerous countries. These treaties seek to provide reciprocal reduced tax rates or exemptions for
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
International Tax Law for Non-Profits
International Tax Law In today’s economic climate non-profit organizations are looking globally to support continuing operations. However, in doing so, non-profits need to understand applicable international tax law and ensure compliance with applicable federal tax laws and IRS guidelines. This is especially important in cities like San Diego where non-profits may have operations in both
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
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
RJS LAW San Diego Welcomes Of Counsel Andrea Cisneros Valdez
June 24, 2021 Andrea Cisneros Valdez has joined RJS LAW San Diego as an Of Counsel attorney. Ms. Cisneros Valdez brings her experience and knowledge to the firm’s Estate/Tax Planning, and Controversy Practice Groups. SAN DIEGO, CALIFORNIA – RJS LAW is pleased to announce Andrea Cisneros Valdez has joined the San Diego office as an Of
The CARES Act – Coronavirus Aid, Relief, and Economic Security
On March 27th, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was put into effect, which will provide taxpayers and businesses significant tax and non-tax relief during these unprecedented times. Individuals and businesses should remain informed about the tax and non-tax implications of the legislation and The CARES Act. WHAT INDIVIDUALS CAN EXPECTIf
Does the CARES Act Create a New Standard of Who is an Employee?
Does the CARES Act Create a New Standard of Who is an Employee? Congress recently based CARES (Coronavirus Aid, Relief, and Economic Security Act) in an effort to ameliorate the effects COVID-19 has had on the economy. Millions of workers have found themselves “out of a job” in recent weeks because of the Coronavirus. Many
California Marijuana Tax
California Marijuana Tax. The legalization of cannabis use and sales is becoming more widespread. What Tax consequences should tax payers be aware of? We opened a cannabis business in a legalized state, is there anything we should be aware of? Yes! With legalization of cannabis comes a myriad of concerns about health, social and criminal