OVDP stands for the “Offshore Voluntary Compliance Program”. This program was used for US individuals who failed to report foreign financial assets to the IRS…

When a business owes payroll taxes or employment taxes to the IRS, the IRS can personally assess one or more individuals the trust fund portion of the payroll…

Specified Individuals and Specified Domestic Entities are required to file the 8938  if the value of the foreign financial assets owned exceeds certain…

Depending upon the terms of the asset purchase agreement or stock purchase agreement, a business owner may have considerable exposure and liability when…

For FBAR purposes a Person is a U.S. individual, corporation, partnership, trust, estate or other entity. That means each of these Persons may have an FBAR…

The FBAR is a report of Foreign Bank Accounts. The US Treasury, through FinCEN, requires US persons who control, or have an interest in, foreign bank accounts…

How “knowledge” may or may not be defined in a stock purchase agreement can impact many of the clauses within a stock purchase agreement.…

If a US person receives a gift or gifts of property from a non-US person, the US person may need to report that gift to the IRS. Reportable gifts from non-US…

The owner or owners of a business may be named individually as a party in an asset purchase agreement. What does this mean for the individual owner of owners?…