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Doctors were sold ill-advised asset protection schemes involving transfer of their financial assets overseas. But the doctors were never advised on the required rigorous reporting of such schemes to ...
The IRS continues to aggressively enforce certain foreign information return obligations. In many cases, these enforcement efforts are automatic—that is, the agency simply imposes the applicable ...
New Proposed Guidance From the IRS on Foreign Trust Transactions and Large Gifts From Non-US Persons
On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed ...
Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud. As the world grows smaller, U.S. citizens and residents ...
As the global landscape continues to shrink, individuals engaging in international transactions, like John in our example, may unwittingly expose themselves to a web of international information ...
The American Institute of CPAs sent comment letters to the Internal Revenue Service requesting changes in two forms used to report on foreign trusts, along with more guidance on energy tax credits and ...
Traditionally, claims related to tax services are the most frequent type of malpractice claim asserted against CPA firms. While that is unwelcome news for tax preparers, most tax claims are not as ...
In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer ...
With a grantor trust, the grantor is still considered the owner of the trust for tax purposes. In a perfect world, the foreign trust will provide the US beneficiary with a K-1 or equivalent so that ...
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