Tax-Favored Foreign Retirement Account One of the biggest headaches for U.S. Taxpayers across the globe who have retirement accounts in foreign countries is having to report them accurately on their U.S. tax return. While reporting these ‘accounts’ on the FBAR and Form 8938 is usually manageable, Forms 3520 and 3520-A can make the reporting […] The post What is a Tax-Favored Foreign Retirement Account, Exceptions appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

  Understanding Foreign Gift Anti-Avoidance Rules One of the biggest concerns that the IRS has when it comes to the reporting of foreign gifts and trusts, is making sure that taxpayers report the information accurately. An issue that has arisen over the years is that taxpayers who may have received a large foreign gift, do […] The post The Anti-Avoidance Rules for Foreign Gifts, Recharacterization appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

  The New Proposed Foreign Trust Regulations  The reporting of foreign trusts and large gifts and inheritances is a very complex aspect of international tax law. That is in part because many aspects of foreign trust laws have not been properly updated to coincide with COLA (Cost of Living Adjustments) — and enforcement protocols in […] The post The New Proposed Foreign Trust and Gift Regulations, 5 Facts appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

For U.S. Resident Owners/Beneficiaries of Foreign Trusts  It is very common for U.S. taxpayers to form trusts — both domestic and foreign. And, trusts can be used for many different purposes. Some of the more common reasons to create a trust are: a basic Revocable Trust to hold real estate rental property; a Charitable Trust […] The post For U.S. Residents with Foreign Trust Tax Status, Example appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

Malta Pension Plans Back in 2021, the United States and Malta issued a CAA (Competent Authority Arrangement) acknowledging, that US Taxpayers’ attempts to utilize certain Malta personal pension and retirement schemes as Roth IRA alternatives were not going to fly. In other words, a person cannot just unload gobbles of cash and assets into a […] The post A Malta Pension Plan Overview of IRS Compliance Options appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

D.C. App. Reverses Farhy, Rules Foreign Information Penalties Valid Unfortunately, U.S. taxpayers across the globe who are required to report their foreign assets to the IRS on various international information reporting forms were dealt a heavy blow by the DC Court of Appeals, when the Appellate Court reversed the Tax Court’s ruling in Farhy. In Farhy, […] The post D.C. Appeals Court Reverses Farhy, Foreign Information Penalty appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

  IRS Foreign Account Penalty Relief For U.S. taxpayers who did not previously report all of their foreign accounts, assets, investments, and income on their tax returns and other international information reporting forms, the Internal Revenue Service offers many different offshore disclosure programs and procedures they can use to safely get into compliance. Unfortunately, the […] The post Relief From IRS Foreign Asset Penalties with SFCP, DFSP or RC? appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

Hiring an Unreported Offshore Assets and Accounts Attorney Ever since the Internal Revenue Service increased its enforcement of offshore disclosure and compliance matters, many less experienced attorneys have jumped in the mix making false representations about their experience — and leading taxpayers astray. And, when these attorneys take on cases that they are not experienced […] The post How to Pick the Right Offshore Disclosure Tax Lawyer appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

  10 FAQs About IRS Form 8938 You Must Know With tax season in full swing, one of the most important international information reporting forms that a U.S. Taxpayer may have to file is IRS Form 8938. The Form 8938 is used by U.S. persons who are required to report foreign assets and accounts in […] The post 10 Facts You Must Know For Filing IRS Form 8938 (Update) appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more

5 Facts About Form 3520 While there are many different types of international tax reporting forms that a U.S. person may have to file each year to disclose their foreign accounts, assets, investments, and income to the Internal Revenue Service — one of the most important tax forms to file is IRS Form 3520. Form […] The post 5 Form 3520 Facts You Should Know (New Update 2024) appeared first on International Tax Attorney | IRS Offshore Voluntary Disclosure ..read more