Foreign Accounts Compliance

Internal Revenue Code § 965 and the Streamlined Procedures

Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign ...
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Advantageous Abandonment of a U.S. Green Card

If you have the status of lawful permanent resident of the United States (i.e., you are a “green card” holder), ...
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New Law Expands U.S. Government’s Discovery of Americans’ Foreign Accounts

The United States taxes its citizens and residents (“U.S. persons”) on their worldwide income.  U.S. persons commonly used foreign financial ...
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Offshore Accounts Remain IRS Enforcement Priority

At the American Bar Association Taxation Section’s annual meeting in Washington, D.C., in May, 2019, IRS representatives said the IRS ...
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