The term “Ordinary Course of Business” is used in many business contracts including an asset purchase agreement and other business acquisition agreements. But…
A Mexican AFORE is effectively a private pension product in Mexico. US Persons who have a Mexican AFORE may be required to report that account on their FBAR,…
Form 5471 is used to report a US persons ownership or interest in shares of a foreign corporation. Certain US persons, defined as U.S. shareholders, are…
When the IRS is considering which individuals to assess the trust fund recovery penalty to, the revenue officer conducts an investigation of the business and…
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…