Offshore Voluntary Disclosure and Tax Compliance

Our team of experienced tax attorneys can help you become compliant with the Internal Revenue Service and minimize or eliminate your exposure to any offshore penalties and other problems. Offshore Voluntary Disclosure Representation One option individuals who have unreported foreign bank accounts and have underreported or failed to disclose foreign...

Pre-Immigration Tax Planning

The decision of a nonresident alien to move to the United States and become a U.S. citizen or resident alien will invoke significant tax considerations involving the interaction of the tax systems of the United States and the alien's current country of residence.  This includes both consequences under U.S. law...

Qualified Quiet Disclosure

Several options exist for individuals with prior undisclosed foreign assets and/or income to become compliant with the IRS.  Two of the more commonly used choices are the Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Taxpayers entering into the Offshore Voluntary Disclosure Program must agree to several requirements. ...

Final Net Investment Income Tax Regulations: December, 2013 Update

Final regulations were issued December 2, 2013, for the net investment income tax imposed under Section 1411. The final regulations adopt with amendments the proposed regulations that were issued in December 2012. Section 1411 imposes a 3.8 percent tax on certain individuals, estates, and trusts with respect to passive income....

Citizens of China can invest in US real estate and pay no tax

With the rapid growth of Chinese economy, overseas property and investment has become a new investment concept for many citizens of China. Domestic policies for house-purchase restrictions and controls, in addition to the global real estate boon, have stimulated the formation of the buyer's in China for overseas property. Further,...

The Qualified Quiet Disclosure: Operating Outside of the IRS Offshore Voluntary Disclosure Initiative

Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the Offshore Voluntary Disclosure Program ("OVDP"). Absent facts indicating willful or reckless intent, an individual may be better...

IRS Targets: Tax Audits of Partnerships, LLCs, and other Pass-through Entities

The Internal Revenue Service announced on November 7, 2013, that it intends to make auditing and examining partnership and other pass-through entities, such as LLCs, S-Corporations, and sole proprietorships a top priority in 2014.  This comes after years of targeting corporations for exam. Pass-Through Entity returns are subject to the...