Entries by Tax Attorney

Opting-Out Of OVDI – Top Questions Answered

IRS has established programs for taxpayers to voluntarily come forward and disclose unreported foreign income and foreign accounts under what the IRS calls the Offshore Voluntary Disclosure Initiative (OVDI). On January 9, 2012 the IRS announced the terms of the 2012 OVDI which requires that taxpayers: (1) File 8 years of back tax returns reflecting […]

Bitcoin Tax Reporting Requirements

Bitcoin has been in the news frequently lately, particularly since the collapse of the Japanese-based Bitcoin exchange, Mt. Gox. Bitcoin is a digital currency and peer-to-peer payment system created in 2009. Since 2009, the use of bitcoins has expanded significantly. Bitcoins can be bought and sold for various currencies, generally through a series of online […]

What To Look For In Selecting A Tax Attorney For OVDI / FBAR

With the full enforcement of the Foreign Account Tax Compliance Act (“FATCA”)starting July 1, 2014, all of the foreign banks have been requiring their U.S. account holders to disclose their social security numbers and other information so that the foreign bank may comply with this law and report their U.S. account holders to the IRS […]

Jeff Kahn hosted on Mr Credit ESPN talk show – Mar 12 2014

Board certified tax attorney Jeffrey B. Kahn discusses the following issues on ESPN’s Mr. Credit. Aired on March 12 2014 a. The Gingrich-Edwards tax loophole…Am I in danger? http://www.cnbc.com/id/101464691 b. What about this tax return software that seems to be everywhere now? Are these causing people the problems I’m assuming they are causing? c. How is […]

Do I need to file Form 8938, “Statement of Specified Foreign Financial Assets”?

In an effort to combat taxpayers who are not reporting income earned on foreign assets, the IRS has implemented a new Form 8938, Statement of Specified Foreign Financial Assets, that beginning with the 2011 tax year must be included with a taxpayer’s Form 1040 if the taxpayer holds specified foreign financial assets with an aggregate […]

U.S. Taxpayers Owning An Interest In A Foreign Entity

A U.S. taxpayer who holds an interest in a foreign entity may not realize that he or she must comply with complex tax reporting requirements as a result of holding an interest in the foreign entity.  First, a U.S. taxpayer who is a shareholder of a “controlled foreign corporation” (CFC), as defined in 26 U.S.C. […]

Court Authorizes IRS to Issue Summonses for Records Relating to U.S. Taxpayers with Offshore Bank Accounts

A number of U.S. taxpayers with beneficial ownership and control over funds held in accounts at Zurcher Kantonalbank and its affiliates (collectively, ZKB) in Switzerland, and The Bank of N.T. Butterfield & Son Limited and its affiliates (collectively, Butterfield) in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland, and the United Kingdom, have […]

HSBC Clients With Asian Accounts Said to Face U.S. Tax Probe

The Justice Department is conducting a criminal investigation of HSBC Holdings Plc clients who may have failed to disclose accounts in India or Singapore to the IRS.  Already some U.S. taxpayers have received a letter from the Justice Department that said prosecutors had “reason to believe that you had an interest in a financial account in India […]