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IRS Matters & Disputes
FBAR Advice IRS
Although, the current status of the Kurotaki v. The United States of America case stands with the US District Court for the District of Hawaii determination on the government’s motion for summary judgment, the Kurotaki case is an interesting analysis of willfulness and other standards relating to the failure to file an FBAR.  This article...
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LT-11 Intent to Levy
IRS Notice LT 11: Intent to Levy If you owe taxes to the Internal Revenue Service you have likely received many notices.  While some notices issued by the IRS may be more benign in nature, certain notices issued by the IRS  require immediate attention.  One such notice that should require immediate attention is the notice...
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IRS Offer in Compromise
Achieving Tax Relief: A Comprehensive Guide to the IRS Offer in Compromise Program You may have heard the ads on the radio, maybe seen them on TV, or companies have even called you about receiving tax relief by settling your tax debts through the IRS Offer in Compromise Program. Are these ads true? Can you...
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Foreign Bank Account Report (FBAR)
Navigating the world of international finance can be a complex task, especially when understanding the requirements and compliance issues related to the Foreign Bank Account Report (FBAR), also known as FinCEN Form 114. This guide aims to comprehensively understand FBAR, its requirements, and how to ensure compliance. What is the FBAR? The U.S. government requires...
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Man standing in front of employees
What is form 5471: Form 5471 is an information reporting form the must be filed with a taxpayer tax return when they meet certain ownership amounts of foreign corporations. Broadly speaking, the form reports who owns the foreign corporation, the current year financial information of the foreign corporation, information related to subpart F and GILTI...
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IRS Form 5471
Summary: Tax-exempt and/or nonprofit organizations may be required to file form 5471. There are several instances where form 5471 would be required. Often, detailed analysis and thorough understanding of the tax rules are required to determine if there is a filing obligation. Failing to file (including late filing) for form is subject to a $10,000...
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IRS Streamlined Offshore Voluntary Disclosure Program (OVDP)
The IRS Streamlined Procedures Q&A’s There are many legitimate reasons United States persons may maintain foreign bank accounts or foreign assets. Perhaps an individual owns real estate in a foreign country, making payments via a foreign bank account easier. Alternatively, an individual has come to the United States for education and remained or married a...
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IRC Section §351 and Property Contributions
Overview of IRC Section §351 and Contributing Property Are you considering establishing a corporation? Perhaps you have considered contributing property as consideration for your interest while another member would like to contribute cash. You may even find yourself in a situation where a third person would like to donate his services in exchange for an...
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Making Charitable Contributions You Should Know About IRS Form 8283
What Is Form 8283? Form 8283 is a tax reporting form used to report donations to charities. If you donate property valued at $500 or more during the calendar year, you must complete and submit Form 8283 within 30 days of making the gift. This includes cash gifts, securities, life insurance policies, annuities, real estate...
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FIRPTA McGuire Law Firm
Many people have questions relating to FIRPTA and the relating withholding tax requirements. Below are common questions and answers related to FIRPTA, but please remember to consult directly with your tax attorney and other tax advisors.  What is FIRPTA? FIRPTA is a withholding tax requirement for a foreign person’s disposition of a U.S. real property...
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