When Must a US taxpayer or Expatriate File Forms 114 and 8938?

When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number still need to understand the risk they are taking when they fail to disclose offshore financial accounts, assets, and income.

Read More in the article from JD Supra

We are attorney/CPAs experts on US International Taxation.  Visit our website at www.taxmeless.com or email ustax@hotmail.com.   Our whatsapp us number is 818-519-9219. Kauffman Nelson LLP.

SPECIFIC PROVISIONS WHICH MAY BE OF INTEREST TO EXPATRIATES FOR 2020

 SPECIFIC ITEMS FOR US EXPATRIATES

Foreign Earned Income Exclusion – 2020 ‐ $107,600   

Gift Tax Annual Exclusion to non‐citizen spouse ‐ $157,000   

Foreign housing base amount (amount of foreign housing not deductible) ‐ $17,216   

Reportable gift threshold from foreign partnership or corporation for reporting on Form 3520

‐ $16,649   

Foreign housing expense (rent and utility) cap ‐ $32,280 unless you are in a high‐cost housing

location as defined by IRS. To see table of high cost housing locations and the relevant cap ‐  see

here (Section 3): www.irs.gov/pub/irs-drop/n-20-13.pdf

Regime for those who have ownership interests in non‐US corporations ‐ Global Intangible

Low‐Taxed Income (GILTI). These rules will cause or have caused many shareholders of non‐ U.S.

corporations to now be subject to tax even if they were not before. Service companies and similar

companies with very limited depreciable assets will most certainly be subject to GILTI and be

required to recognize the corporate earnings as income on the U.S. personal tax return. Please

contact us if you need planning or information on this taxation regime.

One must report overseas assets owned by businesses as well as individuals. So, the reporting

requirements are increasing and the penalties for failure to report continue to be harsh. Not all

foreign holdings must be reported. If, for example, you hold stock in a foreign company through a

U.S. broker, those holdings do not have to be separately reported. However, if you hold any other

types of foreign assets, including bank accounts and securities accounts, please let us know in

your questionnaire. If you have any doubt as to whether any of your assets are foreign, please

discuss those assets with us. Again, this year we will need information on a business’ foreign

holdings as well.

STANDARD YEAR-END PLANNING CONSIDERATIONS

As year-end approaches it is a good time to think about planning moves that may help lower your

tax bill for this year and possibly next. Year-end planning for 2020 takes place during the COVID-19

pandemic, which in addition to its devastating health and mortality impact has widely affected

personal and business finances. New tax rules have been enacted to help mitigate the financial

impact of the disease, some of which should be considered as part of this years' planning, most

notably elimination of required retirement plan distributions, and liberalized charitable deduction

rules.

Major tax changes from recent years generally remain in place, including lower income tax rates,

larger standard deductions, limited itemized deductions, elimination of personal exemptions, an

increased child tax credit, and a lessened alternative minimum tax (AMT) for individuals; and a major

corporate tax rate reduction and elimination of the corporate AMT, limits on interest deductions,

and generous expensing and depreciation rules for businesses. And non-corporate taxpayers with

certain income from pass-through entities may still be entitled to a valuable deduction.

Despite the lack of major year-over-year tax changes, the time-tested approach of deferring income

and accelerating deductions to minimize taxes still works for many taxpayers, as does the bunching

of expenses into this year or next to avoid restrictions and maximize deductions.

We have compiled a list of actions based on current tax rules that may help you save tax dollars if

you act before year-end. Not all actions will apply in your situation, but you (or a family member)

will likely benefit from many of them. We can narrow down the specific actions that you can take

once we meet with you to tailor a particular plan. In the meantime, please review the following list

and contact us at your earliest convenience so that we can advise you on which tax-saving moves to

make:

Year-End Tax Planning Moves for Individuals

... Higher-income earners must be wary of the 3.8% surtax on certain unearned income. The surtax is

3.8% of the lesser of: (1) net investment income (NII), or (2) the excess of modified adjusted gross

income (MAGI) over a threshold amount ($250,000 for joint filers or surviving spouses, $125,000 for

a married individual filing a separate return, and $200,000 in any other case). As year-end nears, a

taxpayer's approach to minimizing or eliminating the 3.8% surtax will depend on his estimated MAGI

and NII for the year. Some taxpayers should consider ways to minimize (e.g., through deferral)

additional NII for the balance of the year, others should try to see if they can reduce MAGI other

than NII, and other individuals will need to consider ways to minimize both NII and other types of

MAGI. An important exception is that NII does not include distributions from IRAs and most other

retirement plans.

... The 0.9% additional Medicare tax also may require higher-income earners to take year-end action.

It applies to individuals whose employment wages and self-employment income total more than a

threshold amount ($250,000 for joint filers, $125,000 for married couples filing separately, and

$200,000 in any other case). Employers must withhold the additional Medicare tax from wages in

excess of $200,000 regardless of filing status or other income. Self-employed persons must take it

into account in figuring estimated tax. There could be situations where an employee may need to

have more withheld toward the end of the year to cover the tax. For example, if an individual earns

$200,000 from one employer during the first half of the year and a like amount from another

employer during the balance of the year, he or she would owe the additional Medicare tax, but

there would be no withholding by either employer for the additional Medicare tax since wages from

each employer don't exceed $200,000.

... Long-term capital gain from sales of assets held for over one year is taxed at 0%, 15% or 20%,

depending on the taxpayer's taxable income. If you hold long-term appreciated-in-value assets,

consider selling enough of them to generate long-term capital gains that can be sheltered by the 0%

rate. The 0% rate generally applies to the excess of long-term capital gain over any short-term

capital loss to the extent that, when added to regular taxable income, it is not more than the

maximum zero rate amount (e.g., $80,000 for a married couple). If the 0% rate applies to long-term

capital gains you took earlier this year for example, you are a joint filer who made a profit of $5,000

on the sale of stock held for more than one year and your other taxable income for 2020 is $75,000

then try not to sell assets yielding a capital loss before year-end, because the first $5,000 of those

losses won't yield a benefit this year. (It will offset $5,000 of capital gain that is already tax-free.)

... Postpone income until 2021 and accelerate deductions into 2020 if doing so will enable you to

claim larger deductions, credits, and other tax breaks for 2020 that are phased out over varying

levels of adjusted gross income (AGI). These include deductible IRA contributions, child tax credits,

higher education tax credits, and deductions for student loan interest. Postponing income also is

desirable for taxpayers who anticipate being in a lower tax bracket next year due to changed

financial circumstances. Note, however, that in some cases, it may pay to actually accelerate income

into 2020. For example, that may be the case for a person who will have a more favorable filing

status this year than next (e.g., head of household versus individual filing status), or who expects to

be in a higher tax bracket next year.

... If you believe a Roth IRA is better than a traditional IRA, consider converting traditional-IRA

money invested in any beaten-down stocks (or mutual funds) into a Roth IRA in 2020 if eligible to do

so. Keep in mind, however, that such a conversion will increase your AGI for 2020, and possibly

reduce tax breaks geared to AGI (or modified AGI).

... It may be advantageous to try to arrange with your employer to defer, until early 2021, a bonus

that may be coming your way. This could cut as well as defer your tax.

... Many taxpayers won't be able to itemize because of the high basic standard deduction amounts

that apply for 2020 ($24,800 for joint filers, $12,400 for singles and for marrieds filing separately,

$18,650 for heads of household), and because many itemized deductions have been reduced or

abolished. Like last year, no more than $10,000 of state and local taxes may be deducted;

miscellaneous itemized deductions (e.g., tax preparation fees and unreimbursed employee

expenses) are not deductible; and personal casualty and theft losses are deductible only if they're

attributable to a federally declared disaster and only to the extent the $100-per-casualty and 10%-

of-AGI limits are met. You can still itemize medical expenses but only to the extent they exceed 7.5%

of your adjusted gross income, state and local taxes up to $10,000, your charitable contributions,

plus interest deductions on a restricted amount of qualifying residence debt, but payments of those

items won't save taxes if they don't cumulatively exceed the standard deduction for your filing

status. Two COVID-related changes for 2020 may be relevant here: (1) Individuals may claim a $300

above-the-line deduction for cash charitable contributions on top of their standard deduction; and

the percentage limit on charitable contributions has been raised from 60% of modified adjusted

gross income (MAGI) to 100%.

Some taxpayers may be able to work around these deduction restrictions by applying a bunching

strategy to pull or push discretionary medical expenses and charitable contributions into the year

where they will do some tax good. For example, a taxpayer who will be able to itemize deductions

this year but not next will benefit by making two years' worth of charitable contributions this year,

instead of spreading out donations over 2020 and 2021. The COVID-related increase for 2020 in the

income-based charitable deduction limit for cash contributions from 60% to 100% of MAGI assists in

this bunching strategy, especially for higher income individuals with the means and disposition to

make large charitable contributions.

... Consider using a credit card to pay deductible expenses before the end of the year. Doing so will

increase your 2020 deductions even if you don't pay your credit card bill until after the end of the

year.

... If you expect to owe state and local income taxes when you file your return next year and you will

be itemizing in 2020, consider asking your employer to increase withholding of state and local taxes

(or pay estimated tax payments of state and local taxes) before year-end to pull the deduction of

those taxes into 2020. But remember that state and local tax deductions are limited to $10,000 per

year, so this strategy is not good to the extent it causes your 2020 state and local tax payments to

exceed $10,000.

... Required minimum distributions (RMDs) that usually must be taken from an IRA or 401(k) plan (or

other employer-sponsored retirement plan) have been waived for 2020. This includes RMDs that

would have been required by April 1 if you hit age 70½ during 2019 (and for non-5% company

owners over age 70½ who retired during 2019 after having deferred taking RMDs until April 1

following their year of retirement). So if you don't have a financial need to take a distribution in

2020, you don't have to. Note that because of a recent law change, plan participants who turn 70½

in 2020 or later needn't take required distributions for any year before the year in which they reach

age 72.

... If you are age 70½ or older by the end of 2020, have traditional IRAs, and especially if you are

unable to itemize your deductions, consider making 2020 charitable donations via qualified

charitable distributions from your IRAs. These distributions are made directly to charities from your

IRAs, and the amount of the contribution is neither included in your gross income nor deductible on

Schedule A, Form 1040. However, you are still entitled to claim the entire standard deduction.

(Previously, those who reached reach age 70½ during a year weren't permitted to make

contributions to a traditional IRA for that year or any later year. While that restriction no longer

applies, the qualified charitable distribution amount must be reduced by contributions to an IRA that

were deducted for any year in which the contributor was age 70½ or older, unless a previous

qualified charitable distribution exclusion was reduced by that post-age 70½ contribution.)

... If you are younger than age 70½ at the end of 2020, you anticipate that you will not itemize your

deductions in later years when you are 70½ or older, and you don't now have any traditional IRAs,

establish and contribute as much as you can to one or more traditional IRAs in 2020. If these

circumstances apply to you, except that you already have one or more traditional IRAs, make

maximum contributions to one or more traditional IRAs in 2020. Then, in the year you reach age

70½, make your charitable donations by way of qualified charitable distributions from your IRA.

Doing this will allow you, in effect, to convert nondeductible charitable contributions that you make

in the year you turn 70½ and later years, into deductible-in-2020 IRA contributions and reductions of

gross income from later year distributions from the IRAs.

... Take an eligible rollover distribution from a qualified retirement plan before the end of 2020 if

you are facing a penalty for underpayment of estimated tax and having your employer increase your

withholding is unavailable or won't sufficiently address the problem. Income tax will be withheld

from the distribution and will be applied toward the taxes owed for 2020. You can then timely roll

over the gross amount of the distribution, i.e., the net amount you received plus the amount of

withheld tax, to a traditional IRA. No part of the distribution will be includible in income for 2020,

but the withheld tax will be applied pro rata over the full 2020 tax year to reduce previous

underpayments of estimated tax.

... Consider increasing the amount you set aside for next year in your employer's health flexible

spending account (FSA) if you set aside too little for this year and anticipate similar medical costs

next year.

... If you become eligible in December of 2020 to make health savings account (HSA) contributions,

you can make a full year's worth of deductible HSA contributions for 2020.

... Make gifts sheltered by the annual gift tax exclusion before the end of the year if doing so may

save gift and estate taxes. The exclusion applies to gifts of up to $15,000 made in 2020 to each of an

unlimited number of individuals. You can't carry over unused exclusions from one year to the next.

Such transfers may save family income taxes where income-earning property is given to family

members in lower income tax brackets who are not subject to the kiddie tax.

... If you were in federally declared disaster area, and you suffered uninsured or unreimbursed

disaster-related losses, keep in mind you can choose to claim them either on the return for the year

the loss occurred (in this instance, the 2020 return normally filed next year), or on the return for the

prior year (2019), generating a quicker refund.

... If you were in a federally declared disaster area, you may want to settle an insurance or damage

claim in 2020 in order to maximize your casualty loss deduction this year.

Year-End Tax-Planning Moves for Businesses & Business Owners

... Taxpayers other than corporations may be entitled to a deduction of up to 20% of their qualified

business income. For 2020, if taxable income exceeds $326,600 for a married couple filing jointly,

$163,300 for singles, marrieds filing separately, and heads of household, the deduction may be

limited based on whether the taxpayer is engaged in a service-type trade or business (such as law,

accounting, health, or consulting), the amount of W-2 wages paid by the trade or business, and/or

the unadjusted basis of qualified property (such as machinery and equipment) held by the trade or

business. The limitations are phased in; for example, the phase-in applies to joint filers with taxable

income between $326,600 and $426,600, and to all other filers with taxable income between

$163,300 and $213,300.

Taxpayers may be able to achieve significant savings with respect to this deduction, by deferring

income or accelerating deductions so as to come under the dollar thresholds (or be subject to a

smaller phaseout of the deduction) for 2020. Depending on their business model, taxpayers also

may be able increase the new deduction by increasing W-2 wages before year-end. The rules are

quite complex, so don't make a move in this area without consulting your tax adviser.

... More small businesses are able to use the cash (as opposed to accrual) method of accounting in

than were allowed to do so in earlier years. To qualify as a small business a taxpayer must, among

other things, satisfy a gross receipts test. For 2020, the gross-receipts test is satisfied if, during a

three-year testing period, average annual gross receipts don't exceed $26 million (the dollar amount

was $25 million for 2018, and for earlier years it was $1 million for most businesses). Cash method

taxpayers may find it a lot easier to shift income, for example by holding off billings till next year or

by accelerating expenses, for example, paying bills early or by making certain prepayments.

... Businesses should consider making expenditures that qualify for the liberalized business property

expensing option. For tax years beginning in 2020, the expensing limit is $1,040,000, and the

investment ceiling limit is $2,590,000. Expensing is generally available for most depreciable property

(other than buildings) and off-the-shelf computer software. It is also available for qualified

improvement property (generally, any interior improvement to a building's interior, but not for

enlargement of a building, elevators or escalators, or the internal structural framework), for roofs,

and for HVAC, fire protection, alarm, and security systems. The generous dollar ceilings mean that

many small and medium sized businesses that make timely purchases will be able to currently

deduct most if not all their outlays for machinery and equipment. What's more, the expensing

deduction is not prorated for the time that the asset is in service during the year. The fact that the

expensing deduction may be claimed in full (if you are otherwise eligible to take it) regardless of how

long the property is in service during the year can be a potent tool for year-end tax planning. Thus,

property acquired and placed in service in the last days of 2020, rather than at the beginning of

2021, can result in a full expensing deduction for 2020.

... Businesses also can claim a 100% bonus first year depreciation deduction for machinery and

equipment bought used (with some exceptions) or new if purchased and placed in service this year,

and for qualified improvement property, described above as related to the expensing deduction.

The 100% write-off is permitted without any proration based on the length of time that an asset is in

service during the tax year. As a result, the 100% bonus first-year write-off is available even if

qualifying assets are in service for only a few days in 2020.

... Businesses may be able to take advantage of the de minimis safe harbor election (also known as

the book-tax conformity election) to expense the costs of lower-cost assets and materials and

supplies, assuming the costs don't have to be capitalized under the Code Sec. 263A uniform

capitalization (UNICAP) rules. To qualify for the election, the cost of a unit of property can't exceed

$5,000 if the taxpayer has an applicable financial statement (AFS; e.g., a certified audited financial

statement along with an independent CPA's report). If there's no AFS, the cost of a unit of property

can't exceed $2,500. Where the UNICAP rules aren't an issue, consider purchasing such qualifying

items before the end of 2020.

... A corporation (other than a large corporation) that anticipates a small net operating loss (NOL) for

2020 (and substantial net income in 2021) may find it worthwhile to accelerate just enough of its

2021 income (or to defer just enough of its 2020 deductions) to create a small amount of net income

for 2020. This will permit the corporation to base its 2021 estimated tax installments on the

relatively small amount of income shown on its 2020 return, rather than having to pay estimated

taxes based on 100% of its much larger 2021 taxable income.

... To reduce 2020 taxable income, consider deferring a debt-cancellation event until 2021.

... To reduce 2020 taxable income, consider disposing of a passive activity in 2020 if doing so will

allow you to deduct suspended passive activity losses.

DUE DATES

∙ As of press time, individuals must file returns by April 15, 2021, for the 2020 tax year, unless you

are living abroad on April 15, 2021 and then you have an AUTOMATIC EXTENSION for filing until June

15, 2021.

-Partnerships must file returns by the 15th day of the third month following the close of the

taxable year (March 15 for calendar‐year taxpayers);  

- C corporation returns are generally due by the 15th day of the fourth month following the close

of the taxable year (April 15 for calendar‐year taxpayers);   

 c-S corporation returns will remain due by the 15th day of the third month of the taxable year

(March 15 for calendar‐year taxpayers); and

-W‐2s and 1099s must be filed by January 31, 2020, for the 2020 tax year.  

IN CONCLUSION

The ideas discussed in this letter are a good way to get you started with year‐end planning, but

they are no substitute for personalized professional assistance. Please do not hesitate to email us

with questions or for additional strategies on reducing your tax liability. We can then set up a phone, skype

 or whatsapp consultation.  EMAIL US    US Phone 949-480-1235

Expatriates That Owe IRS May Lose Their Passports

Over 8 million Americans are estimated to be living overseas.  Many of those live abroad due to debt and amounts owed the IRS for past taxes.  The IRS has a new program which puts those Americans in jeopardy should they return to the USA for a visit. READ MORE HERE

If you need help catching up with your taxes or entering into an offer in compromise or payment plan with the IRS for past due US income taxes, WE CAN HELP.  Email us with your questions or to set up a mini-consultation to solve your past due tax burden.  EMAIL US

DOWNLOAD YOUR EXPATRIATE TAX PLANNING NEWSLETTER

US Expatriate, Nonresident or International Tax Consultations With An Attorney

A "MINI TAX CONSULTATION" IS NOW AVAILABLE with a US Attorney by Phone or Skype: If you have specific tax questions on your personal situation and need to discuss it with an US expatriate international tax expert, with the protection of  Attorney-Client privilege, you can request a "Mini Consultation."   "Mini Consultation" costs a minimum of $300 US for up to 30 minutes of Mr. Nelson's professional legal tax advice over the phone, skype or by  email from any where in the world.         

  No need to visit his office.  If  you send us an outline of your situation, facts and questions in advance, we prepare in advance and this time is extremely productive and usually resolves all of your questions  within the time allowed. Over 900 U.S. expat taxpayers located everywhere in the world  have used "Mini Consultations" to resolve their tax problems and issues.  US Phone (949) 480-1235. US Fax (949) 606-9627 or we can talk on my skype address dondnelson. Email:ddnelson@gmail.com   Payment can easily be made by credit card, or  paypal, or direct  bank transfer. If your questions or problems are URGENT let us know and we can often schedule it on the same day. Learn More About  How your Mini Consultation Works

Don Nelson, Attorney at Law has ever 30 years experience with US expatriate, international and nonresident taxation and representing taxpayers before the IRS.  He is also a partner in Kauffman Nelson LLP Certified Public Accountants.  Read more about his background and experience.

www.TaxMeLess.com

Expats - Home Office Deduction

If are an expatriate employee (of a US or foreign company) or self employed abroad and  you use part of your home for your business, you may qualify to deduct expenses for the business use of your home. Here are six facts from the IRS to help you determine if you qualify for the home office deduction.

1. Generally, in order to claim a deduction for a home office, you must use a part of your home exclusively and regularly for business purposes. In addition, the part of your home that you use for business purposes must also be:

• your principal place of business, or

• a place where you meet with patients, clients or customers in the normal course of your business, or

• a separate structure not attached to your home. Examples might include a studio, workshop, garage or barn. In this case, the structure does not have to be your principal place of business or a place where you meet patients, clients or customers.

2. You do not have to meet the exclusive use test if you use part of your home to store inventory or product samples. The exclusive use test also does not apply if you use part of your home as a daycare facility.

3. The home office deduction may include part of certain costs that you paid for having a home. For example, a part of the rent or allowable mortgage interest, real estate taxes and utilities could qualify. The amount you can deduct usually depends on the percentage of the home used for business.

4. The deduction for some expenses is limited if your gross income from the business use of your home is less than your total business expenses.

5. If you are self-employed, use Form 8829, Expenses for Business Use of Your Home, to figure the amount you can deduct. Report your deduction on Schedule C, Profit or Loss From Business.

6. If you are an employee, you must meet additional rules to claim the deduction. For example, in addition to the above tests, your business use must also be for your employer’s convenience.

If you are an employee of a US or foreign corporation and qualify this deduction goes under miscellaneous deductions on Schedule A.  If you are self employed it goes on your schedule C. You can get more information in IRS Publication 587 which can be downloaded here.

As a US expat, there may be many deductions or other tax savings strategies you may not know about. Read more at www.TaxMeLess.com or at www.expatattorneycpa.com

Expats Guide to Surviving and IRS Audit

The Chairman of Thomson Reuters China has written a guide to help expats survive IRS audits. In the past several years the IRS has hired thousands of new personnel in its International Division and the number of expatriate tax audits are increasing dramatically and will continue to increase in the future. READ THE ARTICLE HERE.

The IRS has discovered that tens of thousands of expats are taking the incorrect foreign earned income exclusion and foreign tax credits which has directly resulted in the increase in Tax Audits. Taxpayers who do their own returns on consumer tax return software often make errors on their returns due to lack of guidance. Remember all such errors may result in additional taxes due, interest and penalties which can often be very high.

  Our firm has represented hundreds of taxpayers in IRS audits with great success. Please email us if you need help. Thanks.   ddnelson@gmail.com

IT IS YOUR OBLIGATION TO KEEP IRS INFORMED OF YOUR CURRENT ADDRESS

Many  US expats who have moved abroad call us after learning of tax liens and other IRS change, letters, etc and state they never received them.  They want to use that as an excuse for their failure to respond or to get  additional taxes, penalties and interest abated.  That does not work.

It is your obligation as a US Taxpayer to keep the IRS Informed of your current mailing address. If you do not, you are solely responsible for any adverse consequences, not the IRS.  If the mail delivery is poor in the country you plan to live, it is best to use a friend or relative's address in the US so you are certain you will receive all IRS communications.

 Change Your IRS Address Records  You can change your address on file with the IRS in several ways:

• Write the new address in the appropriate boxes on your tax return;
• Use Form 8822, Change of Address, to submit an address or name change any time during the year.  It can be downloaded at www.irs.gov;
• Give the IRS written notification of your new address by writing to the IRS center where you file your return. Include your full name, old and new addresses, Social Security Number or Employer Identification Number and signature. If you filed a joint return, be sure to include the information for both taxpayers. If you filed a joint return and have since established separate residences, each spouse should notify the IRS of their new address.

COLLECTING SOCIAL SECURITY WHEN RETIRED ABROAD

You can still get US social security

If you are a U.S. citizen, you may receive your benefits in most foreign countries, usually by check or direct deposit. If you are not a U.S. citizen, the answer is more complicated, with certain rules applying to certain countries. For specifics, see the Social Security publication "Your Payments While You Are Outside the United States." 


You generally must pay into social security for ten years to get benefits. Many US expats who work for foreign employers do not pay into US social security and therefore may not have enough credits to collect benefits.  You cannot receive it just because you are a US Citizen if you did not pay into the system. Read more at www.ssa.gov

IRS Announces 2011 Voluntary Offshore Disclosure Program (new program)

The IRS TODAY announced a New 2011 Voluntary Offshore Disclosure Program which will be available through August 31, 2011. It gives taxpayers who are hiding assets abroad, or not disclosing those assets on their tax returns as required by tax law , or those who failed to  file the required forms disclosing their assets abroad a second chance to come out of the closet. The new program will give participants  reduced penalties from those they would have paid if they did not enter the program. The new program's penalties however are in many circumstances higher than those charged participants in the 2009 Offshore Voluntary Disclosure Program which ended 10/15/09.  Over 15,000 taxpayers participated in the original program and over 3,000 taxpayers have  since that time have filed to  disclose foreign bank accounts which had not previously been disclosed to the IRS.

Read more about the program here.  Our firm counseled and represented many  clients involved in the previous IRS Offshore Disclosure program with great results. Please contact us if you need assistance of an Attorney CPA with this New program. Anything you tell us is totally confidential under the attorney-client privilege rule.

2011 IRS Voluntary Offshore Disclosure Program Frequently Asked Questions and Answers

2010 Year End US Income Tax Planning

Its time to try to reduce your taxes for 2010 by doing year end tax planning.  Our year end tax planning letter is on our website. Click Here to Get Year End Tax Planning Ideas