Have a Foreign Bank Account? What You Need to Know

There are many advantages of having a foreign bank account, such as convenience, hedging against currency risk, etc. For U.S. persons, those advantages have to be weighed against the reporting requirements. Our laws require most foreign bank accounts be reported. There can be stiff civil and criminal penalties for failing to do so. The Foreign……

U.S. Foreign Tax Credit Not Impacted by Repayment of Foreign Tax Refund

The tax assessment and collection process in most foreign countries is markedly different than the process in the U.S. These differences can present a number of challenges for U.S. citizens who reside in foreign countries. In Sotiropoulos v. Commissioner, T.C. Memo. 2017-75, the court considered one of these challenges, namely, how does one determine whether…

Court Considers Economic Substance in S Corp Transactions

The IRS challenges some tax positions by asserting that the transactions lack economic substance. This can allow the government to unwind or ignore transactions that comply with our tax laws if there is no legitimate business purpose for the transactions other than tax savings. There is a growing body of court cases that helps define…

Eight Things You Need to Know About the IRS Offer in Compromise Program

An offer in compromise is a legal agreement between you and the IRS that settles your tax debt for less than the full amount you owe. It provides you with a path for paying off your tax debt and getting a “fresh start.” If you have unpaid tax debts, here are eight things you need…Continue…

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