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Golding & Golding International Tax Lawyers
เข้าร่วมเมื่อ 8 ก.ค. 2015
Eighth Amendment May Apply to FBAR Penalties - Golding & Golding, Board Certified Tax Law Specialist
www.goldinglawyers.com
In the never-ending court saga of Schwarzbaum, a key decision was reached on the issue of FBAR Fines -- whether certain foreign bank account penalties can be considered under the Eighth Amendment as ‘Excessive Fines.’ While the first circuit in the case of Toth (2022) determined that FBAR penalties were not subject to the Eighth Amendment excessive fines clause, the Schwartzbaum court in the Eleventh Circuit Court of Appeals disagreed and found that FBAR fines could be considered under the Eighth Amendment. While in this particular case even under the Eighth Amendment excessive fines clause, the penalties were not reduced by much relative to the overall penalty (which still exceeds $12 million), conceptually it is very important because many taxpayers may find themselves in a situation where they are subject to willfulness penalties for lower valued accounts.
In the never-ending court saga of Schwarzbaum, a key decision was reached on the issue of FBAR Fines -- whether certain foreign bank account penalties can be considered under the Eighth Amendment as ‘Excessive Fines.’ While the first circuit in the case of Toth (2022) determined that FBAR penalties were not subject to the Eighth Amendment excessive fines clause, the Schwartzbaum court in the Eleventh Circuit Court of Appeals disagreed and found that FBAR fines could be considered under the Eighth Amendment. While in this particular case even under the Eighth Amendment excessive fines clause, the penalties were not reduced by much relative to the overall penalty (which still exceeds $12 million), conceptually it is very important because many taxpayers may find themselves in a situation where they are subject to willfulness penalties for lower valued accounts.
มุมมอง: 34
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FBAR Filing 2024: FBAR Filing Requirements and Deadlines (in Under 10 Minutes) - Golding & Golding
มุมมอง 8714 วันที่ผ่านมา
www.goldinglawyers.com FBAR Filing 2024 Each year, Taxpayers considered U.S. persons for tax purposes must report their foreign accounts, assets, and investments on various international information reporting forms to the IRS and FinCEN. While there are many different types of IRS foreign tax forms that a Taxpayer may have to file, the FBAR (Foreign Bank and Financial Account Form) is the form ...
Form 3520 Penalties (In Under 10 Minutes) - Overview of the 3520 Penalty Process & Common Defenses
มุมมอง 5914 วันที่ผ่านมา
www.goldinglawyers.com Form 3520 Penalty Explained A U.S. taxpayer may have to file many different international information reporting forms each year to disclose their foreign accounts, assets, investments, businesses, gifts, and trusts to the IRS. One of the most common types of international information reporting forms that Taxpayers are required to file (especially for those with family mem...
Foreign Trust Reporting Update (in Under 10 Minutes) - New Information (2024) Forms 3520 and 3520-A
มุมมอง 5214 วันที่ผ่านมา
www.goldinglawyers.com When it comes to international tax and reporting, foreign trust tax and reporting are two of the most complicated aspects of annual foreign investment compliance. This is because of many different reasons, such as: -What is a foreign trust? -When is a foreign trust taxable? -When is a foreign trust reportable? -Does the foreign trust qualify for any exceptions (Revenue Pr...
FBAR Examinations/Audits in Under 10 Minutes - Further FBAR Examinations are Coming in 2024 & 2025
มุมมอง 5321 วันที่ผ่านมา
www.goldinglawyers.com/fbar-examinations-foreign-account-audits-how-to-avoid/ The FBAR is a FinCEN form that is used to report foreign bank and financial accounts (aka FinCEN Form 114) to the U.S. Government. In recent years, the Internal Revenue Service has made offshore tax compliance a key enforcement priority, with an emphasis on FBAR reporting. In 2024, the IRS stated that it was significa...
FBAR vs Form 8938 - Do You File the FBAR (FinCEN 114), IRS Form 8938, or Both - Golding & Golding
มุมมอง 7621 วันที่ผ่านมา
www.goldinglawyers.com FBAR & FATCA When it comes to U.S. Taxpayers having to report their foreign accounts, assets, and investments to the U.S. Government, two of the most common international information reporting forms that a Taxpayer may have to file are the FBAR and Form 8938 (FATCA). Both forms require the Taxpayer to report the maximum account value at any time during the year. And, ther...
Visa Holders Living in the US for Under 183 Days May Avoid Most Taxes (Closer Connection Exception)
มุมมอง 6321 วันที่ผ่านมา
www.goldinglawyers.com Closer Connection Exception to the Substantial Presence Test: The U.S. follows a worldwide taxation model. That means the U.S. government taxes U.S. persons on their worldwide income. Foreign nationals who reside in the U.S. and are neither permanent residents nor U.S. citizens may still be subject to worldwide tax and reporting when they meet the IRS substantial presence...
What is Tax Fraud (in Under 10 Minutes) with Examples Golding & Golding - Board Certified Specialist
มุมมอง 63หลายเดือนก่อน
www.goldinglawyers.com/a-guide-to-tax-fraud-and-fraud-penalties-with-examples/ A Primer on Tax Fraud Violations Most IRS tax violations are civil and not criminal. And, while a civil tax violation may result in additional taxes, fines, penalties, and interest it does not result in incarceration (although violating civil orders may result in jail or prison as was the result in the FBAR case of K...
7 Tax Warnings for Green Card Holders in Under 10 Minutes (Golding & Golding, Board Certified)
มุมมอง 256หลายเดือนก่อน
Tax Warnings for Green Card Holders in Under 10 Minutes (Golding & Golding, Board Certified Tax Law Specialist) While becoming a US Permanent Resident/Green Card Holder can have significant immigration benefits, it is important to also consider the U.S. tax implications associated with becoming a permanent resident as well. That is because as a permanent resident, a taxpayer is taxed on their w...
Offshore Voluntary Disclosure in Under 10 Minutes 2024 - Amnesty Limits Penalty (Golding & Golding)
มุมมอง 188หลายเดือนก่อน
2024 IRS Voluntary Disclosure Program Offshore Update: is ... www.goldinglawyers.com/irs-offshore-tax-amnesty-program-how-to-disclose-foreign-accounts/ For the past several years, the Internal Revenue Service has significantly increased enforcement of international tax reporting and compliance. There are many different international information reporting forms that a U.S. taxpayer may have to f...
Explaining FBAR Basics in Under 10 Minutes - Golding & Golding, Board-Certified Tax Law Specialist
มุมมอง 88หลายเดือนก่อน
www.fbarlawyersirs.com/fbar-basics/ The US Government requires US Taxpayers who own foreign assets and accounts to disclose this foreign account information on FinCEN Form 114 otherwise known as the FBAR in addition to filing a US Tax Return. FBAR refers to the Report of Foreign Bank and Financial Accounts, which is filed by US Persons on FinCEN Form 114 and enforced by the Internal Revenue Ser...
2024 IRS Voluntary Disclosure Program Offshore Update: is VDP Your Best Option - Golding & Golding
มุมมอง 146หลายเดือนก่อน
www.goldinglawyers.com/irs-voluntary-disclosure-program-offshore/ IRS Voluntary Disclosure Program Updated Practice When a US Taxpayer is out of compliance with the Internal Revenue Service, they have different tax amnesty options available to voluntarily disclose their unreported money and get into compliance. The IRS Voluntary Disclosure Program is a Federal Government program that provides T...
Delinquent FBAR Procedures for Taxpayers Seeking Compliance in U.S. or Abroad - Golding & Golding
มุมมอง 117หลายเดือนก่อน
www.goldinglawyers.com Delinquent FBAR Submission Procedures While there are many different types of international information reporting forms that a U.S. taxpayer may have to file each year to report their foreign accounts, assets, and investments to the Internal Revenue Service, the FBAR (Foreign Bank and Financial Account Reporting) is the most well-known out of all the foreign forms. Unlike...
Delinquent International Information (Late Form) Return Submission Procedures - Golding & Golding
มุมมอง 63หลายเดือนก่อน
www.irsstreamlinedprocedures.com/delinquent-international-information-return-submission-procedures/ 2024 Delinquent International Information Return Submission Procedures The Penalty Relief Programs for Late International Return Filing For the past several years, the Internal Revenue Service has significantly increased enforcement of international tax reporting and compliance. There are many di...
Expat Tax Complications - Must US Expats Pay US Taxes & How to Fix Common Errors (Golding & Golding)
มุมมอง 69หลายเดือนก่อน
Expat Tax Complications For U.S. expats that live in a foreign country, unless they have formally expatriated and renounced their US citizenship or terminated their lawful long-term permanent residency, they are required to file U.S. tax returns just as if they resided in the United States (subject to making a treaty election if applicable). Likewise, many expats who live in foreign countries w...
How to Certify Non Willfulness and Avoid Streamlined Mistakes (Golding & Golding, Board Certified)
มุมมอง 67หลายเดือนก่อน
How to Certify Non Willfulness and Avoid Streamlined Mistakes (Golding & Golding, Board Certified)
Court Holds FBAR Error on Schedule B (Foreign Accounts) Can Still be Non-Willful - Golding & Golding
มุมมอง 68หลายเดือนก่อน
Court Holds FBAR Error on Schedule B (Foreign Accounts) Can Still be Non-Willful - Golding & Golding
Form 8938 Threshold Requirements with Examples (Golding & Golding, Board-Certified Tax Specialist)
มุมมอง 68หลายเดือนก่อน
Form 8938 Threshold Requirements with Examples (Golding & Golding, Board-Certified Tax Specialist)
Are Foreign Pensions Considered Trust for Form 3520 or 3520-A Filing Purposes (Golding and Golding)
มุมมอง 59หลายเดือนก่อน
Are Foreign Pensions Considered Trust for Form 3520 or 3520-A Filing Purposes (Golding and Golding)
Defenses to Late-Filed IRS Form 3520 Penalties (Golding & Golding, Board-Certified Tax Specialist)
มุมมอง 68หลายเดือนก่อน
Defenses to Late-Filed IRS Form 3520 Penalties (Golding & Golding, Board-Certified Tax Specialist)
Is an IRS Streamlined Disclosure Always Your Best Option or Not (Golding & Golding, Board Certified)
มุมมอง 67หลายเดือนก่อน
Is an IRS Streamlined Disclosure Always Your Best Option or Not (Golding & Golding, Board Certified)
Foreign Retirement Plan Tax Form Requirements (Golding & Golding, Board-Certified Tax Specialist)
มุมมอง 145หลายเดือนก่อน
Foreign Retirement Plan Tax Form Requirements (Golding & Golding, Board-Certified Tax Specialist)
Are In-Person Interviews Required for Failing to File Form 3520, 8938, or 5471 (Golding & Golding)
มุมมอง 51หลายเดือนก่อน
Are In-Person Interviews Required for Failing to File Form 3520, 8938, or 5471 (Golding & Golding)
Examples of How to Determine FBAR Non-Willfulness and Willfulness: Golding & Golding, Tax Specialist
มุมมอง 106หลายเดือนก่อน
Examples of How to Determine FBAR Non-Willfulness and Willfulness: Golding & Golding, Tax Specialist
5 Key Facts About IRS Form 3520-A You Must Know (Golding & Golding, Board-Certified Tax Specialist)
มุมมอง 70หลายเดือนก่อน
5 Key Facts About IRS Form 3520-A You Must Know (Golding & Golding, Board-Certified Tax Specialist)
5 Examples of Citizenship-Based Taxation and Worldwide Income for U.S. Persons (Golding & Golding)
มุมมอง 612 หลายเดือนก่อน
5 Examples of Citizenship-Based Taxation and Worldwide Income for U.S. Persons (Golding & Golding)
Form 5471 (New): Introduction to the Basics of Filing Form 5471 (Golding & Golding Tax Specialist)
มุมมอง 632 หลายเดือนก่อน
Form 5471 (New): Introduction to the Basics of Filing Form 5471 (Golding & Golding Tax Specialist)
Difference Between Willful and Non-Willful Penalties: Analyzing FBAR Violations (Golding & Golding)
มุมมอง 1272 หลายเดือนก่อน
Difference Between Willful and Non-Willful Penalties: Analyzing FBAR Violations (Golding & Golding)
Citizenship-Based Taxation, Worldwide Income and Foreign Account Reporting (Golding & Golding)
มุมมอง 1003 หลายเดือนก่อน
Citizenship-Based Taxation, Worldwide Income and Foreign Account Reporting (Golding & Golding)
Tax Consequences for Americans Abroad Returning to Live in the United States (Golding & Golding)
มุมมอง 773 หลายเดือนก่อน
Tax Consequences for Americans Abroad Returning to Live in the United States (Golding & Golding)