IRS Tax Amnesty After Trump Reform
The Tax Cuts and Jobs Act (“TCJA”), encated at the end of 2017, undoubtedly brought many significant changes to the U.S. tax system. Because the TCJA changed the Tax Code in so many areas, it’s…
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Willful FBAR Penalty Limit
When taxpayers are caught late filing the FBAR, the IRS will assess penalties based on whether it thinks the individual’s conduct was willful or non-willful. The difference in penalty regimes are…
Read MoreVoluntary Disclosure Program for Willful Tax Delinquency
On September 28, 2018, the IRS officially terminated its increasingly unpopular Offshore Voluntary Disclosure Program (OVDP), leaving willfully delinquent taxpayers open to the full gambit of…
Read MoreForeign Earned Income Exclusion Disallowed for Military Contractor
Continuing the trend of recent cases, the Tax Court again disallowed the foreign earned income exclusion (“FEIE”) in the case of a contractor for the U.S. military who worked in Afghanistan during…
Read MoreIRS Adds New International Tax Compliance Issues to Its Audit List
Previously, we’ve blogged about the IRS’s selection of a group of international tax compliance issues that became part of its issue-focused audit strategy. The IRS has since added more international…
Read MoreTransition Tax Rates
Owners of fiscal-year foreign corporations (i.e., corporations that do not have a tax year end of December 31) owing “transition tax” generally have the luxury of waiting until next year’s tax season…
Read MoreThe Streamlined Amnesty Program’s Non-Willful Certification (Form 14653)
A key requirement for participating in the IRS’s Streamlined amnesty program is a certification by the late filer that his or her delinquency was the result of non-willful conduct.
Read MoreCombat-Zone Contract Workers to Claim Foreign Exclusion
In a recent online update, the IRS reminded taxpayers that starting with the 2018 tax year, contractors or employees of contractors supporting the U.S. Armed Forces in designated combat zones will…
Read MoreStreamlined Procedures Physical Presence Test
Currently, over 9 million U.S. citizens are living outside the United States. More and more expats are beginning to realize that their U.S. tax obligations did not end upon their move abroad. Many…
Read MoreChanges to the Child Tax Credit
While Trump’s tax reform made a number of important changes to the U.S. tax system, there is one reform that is particularly important for U.S. parents living abroad. The Tax Cuts and Jobs Act…
Read MoreLimitation on State and Local Tax Deduction
Since the enactment of Trump’s Tax Cuts and Jobs Act (“TCJA”), state Democrat leaders have taken aim to counteract the impact of the federal bill through state legislation and other means. In a…
Read MoreIRS Audit Strategy
In January of 2017, the IRS’s Large Business and International division (LB&I) selected a group of tax compliance issues that it determined would become part of its new issue-focused audit strategy.…
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