by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
There’s a lot of ambiguity in the classic case of somebody squirreling away money. In a lot of cases, it’s not so easy to figure out, and the IRS is not coming forward with a lot of guidance because they’re probably trying to figure it out themselves.
One of the situations that’s pretty [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
One of the questions that comes up from time to time is: what about business accounts?
Specifically, this question applies to U.S. citizens or residents who live overseas and own a business. The business obviously is going to have bank accounts. It may have a merchant account to process credit cards. What if [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
There’s a little golden ticket in the FAQ the IRS has just published.
This has to do with people who did not file the magic forms disclosing ownership of a foreign corporation (Form 5471) or foreign trust (Form 3520). What if you had no tax due, but you just screwed up on that [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
If you have:
Offshore bank accounts;
Unreported foreign income;
Foreign corporations you never owned up to; or
Foreign trusts that have money in them; and
Your paperwork wasn’t done correctly, and/or you didn’t pay the tax you should have, then:
This amnesty is for you.
The foreign bank account amnesty closes on September 23, 2009. Go through it, and you’ll clean [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
One of the questions that comes up again and again and again is, “I had my money in one account and then I moved it to another account. The IRS is saying that you have to pay 20 percent of the high balance. Do I have to pay 20 percent when it was in the [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
One of the deals with the amnesty is that you’ve got to get to the IRS before they find you. If they find you, it’s not voluntary any more, is it, because they’re after you and they’re chasing you.
One of the problems now facing offshore account holders is this: there’s this giant [...]
by Phil Hodgen, Hodgen Law Group PC on June 26, 2009
One of the interesting things about this whole amnesty process is that it covers the years 2003 through 2008. The question that inevitably comes up is, what about the years before 2003?
For instance, let’s say you had a real estate sale in 2002 outside the United States, and you made a big capital gain [...]
by Phil Hodgen, Hodgen Law Group PC on June 25, 2009
The new IRS FAQ kinda sorta gave you an extension for 2008.
The FBAR (Form TD F 90-22.1) has a filing deadline of June 30, 2009. That means the form has to be in Detroit on June 30. Postmarked by June 30 doesn’t count.
The new IRS FAQ says (at #43) that if you filed [...]
by Phil Hodgen, Hodgen Law Group PC on June 12, 2009
I just got off a 90 minute conference call co-sponsored by the American Bar Association and the AICPA. Some government people were on the call, to explain the FBAR amnesty, the filing requirements, and what’s coming over the horizon.
They’re coming out with a new official IRS publication later in the year. It has [...]
by Phil Hodgen, Hodgen Law Group PC on June 4, 2009
Here’s an article from Der Spiegel about a convicted criminal in Germany. He’s hoping to buy down his sentence by offering up incriminating private bank information about 2,700 unsuspecting souls. His plan isn’t working quite as well as he had hoped, but what do you bet that the German tax authorities will get their hands [...]