Blog Archives: Audits & Tax Issues

In this post, I look at the recent US Tax Court Case Tice v IRS (April 10, 2023). This USVI case has major implications for those of us living and working in Puerto Rico under Acts 20, 22, and 60 (the more recent version of the law). Anyone in Puerto Rico using these tax decrees

In this post, I’ll look at the 2020 IRS offers to low and medium-income expatriates – US citizens that wish to give up their US passports and escape the IRS once and for all. This expatriate tax deal is very limited in scope. But, if you qualify, you should act now to expatriate!  Editor’s Note:

The IRS will end the Offshore Voluntary Disclosure Program on September 28, 2018. If you haven’t come forward by that time, you’re out of luck. In fact, the IRS has already begun to ramp down the 2014 Offshore Voluntary Disclosure Program and it’s becoming more difficult to get cases through. From the IRS website, “Taxpayers

The US IRS will begin certifying tax debts on January 22, 2018. If you have a “seriously delinquent” tax debt, your passport can be revoked. Likewise, the government can refuse to renew your passport if you owe more than $50,000. Here’s where you can travel without a passport after it’s been revoked by the IRS.

The IRS smells blood in the water over Bitcoin and it’s coming hard for Coinbase users. The war on cryptocurrency is just getting started and it’s going to get ugly fast. Expect US citizens with US crypto accounts to be put in jail to send a message to the rest of us to fall in

In this article I’ll explain how to eliminate Subpart F Foreign Base Company Service Income issues in an offshore corporation.  Subpart F issues are the most common tax planning hurdles to overcome when you have a division of a US company operating abroad. Subpart F applies to income of a Controlled Foreign Corporation (CFC). This

Much like the NSA, the IRS data collection machine is building a file on all Americans. It’s online now and will be ready to use in all audits within one year. The IRS collects more useful data on you than does the NSA and will begin making it available to auditors shortly. Some IRS data

There’s no worse feeling in the world than coming home to a letter from the IRS telling you that you are being audited … until you get notice of an offshore IRS audit. No matter how organized you are, you should fear the great IRS. If you have unreported accounts or become the subject of

Foreign Account Tax Compliance Act is finally here and you can be sure that the impact of FATCA will be severe. This brief article considers the impact of FATCA on Americans living, working, or investing overseas. FATCA is founded in a U.S. tax code that attacks small business and lavishes tax holidays on the wealthy

If you thought an IRS audit was bad news, just wait until the IRS agents with guns come and take you down.  The IRS Criminal Investigation Division, or CID, can seize your records, tap your phone, spy on your emails, and treat you like a major criminal – all for failing to pay up.  The

The U.K. tax authority to allow IRS Levy type actions. If you owe the HMRC, they now have the authority to seize your bank account and raid your assets, just like an IRS levy. Now, it’s no surprise that the U.K. is following in the footsteps of the mighty IRS levy. It’s just interesting that

If you have a tax debt, there are a number of IRS fees for setting up a payment plan or installment agreement. These IRS fees can add up quickly if you default and need to reapply. The IRS fee for setting up a payment plan on direct debit from your bank account is $52. This

I want to use today’s post to clear up a common misconception. Yes, the IRS can seize your IRA or other retirement account. Yes, the great collector is exempt from state laws protecting your retirement account and can take what it wants at any time … unless you take steps to protect yourself. Specifically, the

A few days ago I wrote an article on dealing with the IRS as an expat.  Apparently, a number of you are carrying tax debt and are concerned with the IRS collection statute – how long the IRS has to collect that tax debt.  This article is specifically for those living abroad that owe the

For most Americans, the IRS audit statute, the amount of time the IRS has to come after you once you have filed your return, is three years.  Not so for those with foreign accounts and foreign assets.  In most cases, the IRS has six years to audit your international investments. First, let’s review the IRS

If you are a U.S. citizen living abroad, you have the same rights and responsibilities when it comes to your expat tax debt as those stuck in America.  The IRS has ever increasing powers to collect on that expat tax debt, so it is in your best interest to get into compliance and make arrangements

If you have unreported offshore bank accounts or foreign assets, the IRS has one last best offer called the 2014 IRS Offshore Settlement Program.  Come forward and, if you are living offshore, pay no penalties.  If you are living in the U.S., pay only 5% for a fresh start. This, the third installment of the

If you are a U.S. citizen living, working or investing abroad, you need to understand the difference between Offshore Tax Fraud and International Tax Planning.  Offshore Tax Fraud is a crime while tax planning is the proper use of the U.S. tax code to minimize your taxes.  There are many benefits to going offshore, but

Today I’m taking time out from my offshore beat to warn you about the CTR.  An IRS Currency Transaction Report is a form filed by U.S. banks and casinos each time you make a deposit or withdrawal of $10,000 or more.  It is filed in secret, without your knowledge, you don’t receive a copy, and

Are you considering forming a cheap offshore company?  Has some scammer in Nevis promised you tax freedom and privacy?  Forming a cheap offshore company that does not include U.S. tax compliance is a roadmap to disaster for the American living, working or investing abroad. How much would you be looking at in penalties for using