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Blog

Employee Stock Options

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Successful businesses will have successful, driven, and strong employees.  Often businesses are faced with questions and issues regarding maintaining employees, hiring the right employees, and incentivizing employees.  Incentive compensation arrangements are often used by large and small businesses as a means by which to reward employees, as well as a benefit to individuals the business […]

Direct Stock Acquisition and Reverse Triangular Merger

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There are multiple options to implement the acquisition of a business.  The purchaser or acquirer could purchase the stock of the target corporation, or the assets of the target corporation.  If the stock of the target corporation is to be purchased there are multiple options and variations by which the stock can be acquired.  The […]

Constructive Ownership Within Foreign Corporations

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Under the context of controlled foreign corporations, a U.S. shareholder is defined as a U.S. Person who owns or is considered as owning 10% or more of the total combined voting power of all classes of stock entitled to vote of a foreign corporation.  Does this language mean that constructive ownership is considered when determining […]

Streamlined OVDP by Denver Tax Attorney

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What is the Streamlined Offshore Voluntary Disclosure Program (OVDP)?  Simply put, the Streamlined OVDP is a program established by the IRS that may be considered “shortened” or “simpler” than the normal OVDP, and has a reduced or lesser penalty of 5% in comparison to the OVDP.  Certain criteria must be met to be eligible for […]

Who Enforces FBAR?

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If you have foreign bank accounts or interests in foreign assets, you may be required to file the FBAR, which is the reporting of foreign bank and financial accounts.  That being said, who enforces the FBAR regulations, and collects on penalties that have been assessed?  FinCEN has directed that the enforcement of the FBAR be […]

IRS Supporting Document Request

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Taxpayers may receive a IRS Supporting Document Request from the Internal Revenue Service requesting supporting documents for certain items, issues or positions taken on a tax return.  Common issues of which the IRS would request a taxpayer support could be IRS Filing Status.  For example, if a taxpayer filed head of household, the IRS may […]

What is FinCEN

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FinCEN is the Financial Crimes Enforcement Network.  The goal and objective of FinCEN is to monitor financial institutions through regulations that require certain record keeping, record maintenance and reporting.  Because many crimes such as illegal drug trafficking, terrorism and others involve large sums of money and the use of financial institution, FinCEN and other law […]