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Federal Taxation

  • When Can a Taxpayer Use the Streamlined Filing Procedures to Disclose Unreported Foreign Assets?

    By:
    Bryan C. Skarlatos, Esq.
    |
    May 1, 2015
    Many taxpayers have foreign assets that they have not reported on prior years’ tax returns, and they have several options to address this noncompliance. 

  • Choices for Taxpayers with Unreported Foreign Assets: Voluntary Disclosure, Streamlined Submission, or Run Away and Hide?

    By:
    Bryan C. Skarlatos, Esq.
    |
    Apr 1, 2015

    Recently, many tax return preparers have learned that a number of their clients failed to report their interest in a foreign bank account, corporation or trust to the IRS.  Because the Foreign Asset Tax Compliance Act requires foreign financial institutions to report their U.S. depositors to the IRS, the IRS is more likely to discover non-reporting taxpayers.  Furthermore, in light of more stringent reporting requirements, recent publicity and IRS enforcement action focused on non-reporters of foreign assets, all tax preparers should ask their clients whether they have failed to report foreign assets to the IRS.  When a practitioner learns of a client’s unreported foreign assets, what should he or she do?  

  • Obama’s Budget Proposal to Tax Unrepatriated Foreign Earnings

    By:
    LISA S. GOLDMAN, CPA, AND THOMAS V. RUTA, CPA
    |
    Mar 1, 2015
    President Obama’s 2016 Budget contains a proposal to end "deferral” of tax on income earned in Controlled Foreign Corporations (CFC).

  • Virtual Currency Exchange Accounts, Hosted Wallet Services, and Vault Services Located Abroad May Trigger FBAR Filing Requirements

    By:
    Keith Miller, Richard Peterson and Joseph Cutler
    |
    Feb 1, 2015
    As the title suggests, there remains an open question as to whether virtual currency accounts, hosted wallet services and vault services located abroad may trigger FBAR filing requirements. Based on case law and the probability of FinCEN deciding to treat virtual currency the same as money, it appears likely that the FBAR filing requirements applicable to monetary accounts will also be applied to accounts funded with virtual currency.

  • Charitable Solicitation Across State Lines: What You Need To Know When Your Charity Clients Engage in Multi-State Fundraising Activities

    By:
    Seth Perlman, Esq. and Tracy L. Boak, Esq.
    |
    Feb 1, 2015
    Currently, 45 states, as well as the District of Columbia have some degree of statutory regulation of charitable solicitation activity conducted within their borders. Many, although not all states, require registration and reporting.

  • Dealing with Virtual Currency? Taxation, Reporting FBARs, and FATCA Worries

    By:
    Keith Miller, Richard Peterson and Joseph Cutler
    |
    Jan 1, 2015
    You or your client decide to jump into the exciting but volatile world of Bitcoin and virtual currencies. What are some of the most important tax-related implications of dealing in virtual currency, and what are the hidden reporting requirements associated with such transactions?

  • Qualified Longevity Annuity Contracts – Something New Under the Sun

    By:
    Bruce Resnik, JD, CPA/PFS
    |
    Dec 1, 2014
    On July 2, 2014, the Internal Revenue Service promulgated new regulations to the Internal Revenue Code which permitted the use of a new type of deferred annuity contract called a “Qualified Longevity Annuity Contract” (QLAC) to be used in conjunction with tax-qualified defined contribution plans and IRA’s. The purpose of the regulations was to make the purchase of lifetime annuities more attractive within retirement plans and help individuals to secure lifetime guaranteed monthly income no matter how long they live.
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