The recent pandemic has caused changes to our lives in multiple ways, some only for the short term hopefully, but surely some aspects of our lives will change for the long term. For instance, in the short term, grocery shopping has become a major inconvenience, and for some, it is a minor inconvenience not knowing when your next haircut is going to be. In the long term, employment patterns will be altered greatly as social distancing and work from home might become the ... Keep Reading »
Get Ready: IRS to End OVDP
Recently, I discussed the impact of so-called “soft letters” sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues (see this generic example of an IRS soft letter). As my prior piece predicted, the IRS announced the Offshore Voluntary Disclosure Program (OVDP) will close to new applicants on September 28, 2018. Now that the IRS has set a date certain for the OVDP to close, non-compliant taxpayers wishing to enter the OVDP should ... Keep Reading »
A Day of Reckoning for Recalcitrant Taxpayers?
Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of compliance programs to give taxpayers with undeclared offshore accounts the opportunity to make voluntary disclosures regarding offshore income and accounts in exchange for fixed civil penalties and the assurance that criminal penalties would not be ... Keep Reading »
How to Manage Foreign Trusts With U.S. Beneficiaries
Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth. If you get cash or other benefits from a foreign trust, you should be aware of the special tax rules which apply to the non-U.S. trust and your beneficial interest in it. Non-U.S. trusts with U.S. beneficiaries are subject to an extra layer of special rules and complexities which you will need to ... Keep Reading »