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...Read More

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...Read More

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...Read More

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...Read More

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...Read More

Lawsuit Settlements And Taxes Lawsuits are one of those things that people always want to avoid. They don’t like being sued and don’t like paying up. When it comes to lawsuits, there are some exceptions. For example, most personal injury claims will not be taxed. This includes cases where someone falls off a ladder, slips,...Read More

IRS Special Agents & Criminal Investigations The Internal Revenue Service performs criminal investigations into individuals suspected of tax evasion, money laundering, drug trafficking, and other crimes. These investigations are conducted primarily by special agents assigned to the Criminal Investigation Division (CID). However, several sources of criminal investigation data are used by CID investigators. A Denver...Read More

Can the IRS Take Your Passport? Congress passed legislation in January 2018 that defines people who owe more than $50,000 in federal income taxes as “seriously delinquent” and risk losing their passport. This classification triggers a process where the IRS sends out notices to taxpayers who are overdue on payments. If you ignore those notices,...Read More

What Is An Abusive Tax Scheme? You may have heard of a program or tax scheme that promises to eliminate or substantially lessen your tax burden and taxes due to the Internal Revenue Service. A promoter of such a scheme will likely use financial instruments such as a trust or pass-through entities such as a...Read More

For many individuals, the Streamlined Offshore Voluntary Disclosure Program provided welcome relief in comparison to the “initial” Offshore Voluntary Disclosure Program.  Many taxpayers with foreign accounts and assets contact wonder what forms and documents must be filed to apply for the Streamlined Offshore Voluntary Disclosure Program.  In general, taxpayer’s must file the necessary FBARs, amend...Read More