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Income Tax Systems

INCOME TAX SYSTEMS

Understanding Global Income Tax Systems Understanding how and when the United States imposes federal income tax on its U.S. Tax Residents in cross border transactions has long been a source of confusion to U.S. taxpayers. In fact, in some cases,…
Financial crimes
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Former Harvard Chemistry Chair indicted for failing to file FBAR and filing false tax returns

IRS Hard at Work Despite the Pandemic Individuals, who have failed to report their foreign financial accounts, may feel a sense of relief, in light of the corona virus and its effects on IRS investigations. Better think again! The DOJ recently…
FBAR non willful penalty dilemma
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Courts Split on FBAR non-willful Penalty

Should FBAR non-willful penalty be charged per form or per account? The Courts have recently addressed the issue of whether the FBAR Non-Willful penalty should be assessed per form rather than per account with conflicting results.  InUnited…
Cash Intensive Business and the IRS

Cash Intensive Businesses & the IRS; a marriage made in Hell

Cash intensive businesses Operating a cash intensive business is often accompanied by poor record keeping as well as the lack of any meaningful internal controls. These two factors make it difficult, if not impossible, to determine the taxpayer’s…
FBAR Quiet disclosures
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Quiet Disclosure Guilty Plea

Florida man pleads guilty to tax evasion and hiding funds around the world In April 2020, a Florida man pleaded guilty to tax evasion and the willful failure to file FBAR’s. What makes this case particularly interesting is that the taxpayer…
Investment Retirement Account

Real Estate Ownership in a self-directed Investment Retirement Account; avoiding the hidden risks

 Real estate ownership in a Self-Directed Investment Retirement Account (IRA) can provide certain tax benefits to taxpayers who are considering an investment in real estate. However, a retirement account considering such a strategy should be…
Michael Avenatti Case on Criminal Tax
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Bank Fraud and Criminal Tax Charges Against Michael Avenatti

Michael Avenatti’s Indictment The temptation to use unfilled or altered tax returns as well as doctored financial statements for purposes of securing a bank loan, while not common, does occur. This practice typically occurs where an individual…
Taxing Foreign Corporations
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Taxing Foreign Corporations in the Digital Age

Effectively Connected Income and it's Tax Consequences Foreign entities that deliver digital goods and services using the internet as a point of distribution may be subject to U.S. income tax. The nature and character of the goods and services…
Qualified Business Income Deduction 2

Good News for Rental Property Owners; Qualified Business Deduction

Business Income Deduction for Taxpayer On September 24, 2019, the IRS issued Revenue Procedure 2019-38  now permitting  certain taxpayers who hold an interest  or interests in rental real estate to be treated as a trade or business for purposes…
TFR and Fraudulent conveyances
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Trust Fund Recovery Penalty; Consequences of Fraudulent Conveyances

Fraudulent Conveyances in Employment Taxes Employers who willfully fail to remit an employee’s withholding to the IRS are liable to the IRS for the “trust fund recovery penalty” (TFRP). Generally, the IRS will assess the Penalty against…