January 2019

FBAR examination?  Find out how to avoid having the IRS succeed in imposing the larger penalty for willful behavior.

First and foremost, an FBAR battle is being waged in federal courts across the country where taxpayers have been seeking to avoid the imposition of the maximum FBAR willfulness civil penalty. Faced with an adverse result during an IRS civil examination or administrative appeal, taxpayers have turned to litigating the civil penalties in federal court

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Withholding Tax on Foreign Partners’ Share of Effectively Connected Income IRC Section 1446

One of the consequences of Trump’s Tax Reform is it’s treatment of Partnerships – particularly those with Foreign Partners.  Withholding is now required. A partnership (foreign or domestic) that has income effectively connected with a U.S. trade or business (or income treated as effectively connected) must pay a withholding tax on the effectively connected taxable

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Beware The Hidden Tax That Could Be On The Rise

The federal accumulated earnings tax (AET) is imposed on companies that have retained earnings deemed unreasonable and in excess of the ordinary by the IRS. Essentially, this tax encourages companies to issue dividends rather than retain the earnings. And it could impact taxation related to C corporations, which tend to accumulate their earnings or profits

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