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Recent blog posts

undisclosed foreign assets, offshore tax compliance, San Jose tax lawyer, offshore voluntary disclosure program, IRSRecently, we examined the options taxpayers have to achieve compliance when they have undisclosed foreign assets. One key method of compliance that the IRS has provided in recent years is the Offshore Voluntary Disclosure Program (OVDP). The program allows taxpayers to report their offshore assets and become compliant while minimizing their civil penalties and avoiding criminal prosecution. However, the IRS recently announced that it will be ending the OVDP on September 28, 2018.

Changing Options for Offshore Tax Compliance

The OVDP was launched in 2009, and the current version of the program has been in effect since 2014. The IRS has reported that since the OVDP was implemented, more than 56,000 taxpayers have used the program to achieve compliance—$11.1 billion in taxes, penalties, and interest have been paid. However, the number of people participating in the program has declined from a high of 18,000 people in 2011 to 600 in 2017.

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San Jose tax attorney, tax reform, Tax Cuts and Jobs Act, business auto deductions, tax codeThe Tax Cuts and Jobs Act of 2017 made seismic changes to tax law in the United States, and individual taxpayers, small businesses, and large corporations are working to determine how they will be affected by the updates that will be going into effect in the near future.

One aspect of the new law that many may not be aware of concerns vehicles purchased or leased by businesses. It is essential that business owners be aware of how these changes can impact the deductions they may claim.

Business Auto Deductions

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San Jose tax lawyer, streamlined compliance, offshore tax evasion, taxpayers, offshore assetsIn a recent blog, we discussed how U.S. taxpayers can become compliant with the IRS’s requirements for reporting foreign financial assets through the Offshore Voluntary Disclosure Program (OVDP). While the OVDP provides people with the ability to address outstanding offshore tax issues, it applies to people who have willfully failed to disclose foreign assets, and meeting its requirements can result in significant expenses but also can avoid significant penalties. For people whose failure to disclose offshore assets was non-willful, another option is available: streamlined compliance.

Eligibility for Streamlined Compliance

Streamlined compliance is available for individual U.S. taxpayers, and it consists of two programs: the Streamlined Foreign Offshore Procedures (for U.S. citizens or lawful permanent residents who lived outside of the United States for at least 330 days in one of the three previous years) and the Streamlined Domestic Offshore Procedures (for U.S. taxpayers who do not meet the non-residency requirement).

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San Jose offshore tax compliance lawyer, OVDP, offshore tax evasion, offshore assets, OVDP processUnder the Internal Revenue Code, taxpayers are required to include all income on their tax return, including interest accrued on funds held offshore.

Under the Foreign Account Tax Compliance Act (FATCA), taxpayers in the United States are required to report financial assets that are held in foreign countries to the IRS. Failure to report their income or these assets can result in both civil and criminal penalties for offshore tax evasion.

To help people and organizations who own offshore funds or assets become compliant, the IRS provides two resolutions: the Offshore Voluntary Disclosure Program (OVDP) and streamlined compliance. In this blog, we examine the requirements and procedures of the OVDP.

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San Jose tax attorney, IRS partnership audit, partnership audits, tax audits, tax lawIn recent months, much of the discussion surrounding tax laws in the United States has focused on the changes made by the Tax Cuts and Jobs Act of 2017. Yet while individuals and businesses should understand how they will be affected by tax reform, they should additionally be aware of recent new rules that govern tax audits.

The Centralized Partnership Audit Regime

Under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), the Internal Revenue Service (IRS) had certain rules for assessing and collecting taxes for partnerships. Audits of large partnerships, such as hedge funds or private equity firms, required individual audits of every partner. The Bipartisan Budget Act of 2015 (BBA) established a new, centralized audit regime, allowing the IRS to audit partnerships as a whole. This new regime will apply to partnership tax years beginning after December 31, 2017.

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