Part 1: U.S. Tax Consequences of an Australian Superannuation Retirement Account

On behalf of Frost Law posted in on August 22, 2022.

Retirement accounts can be an integral part of wealth accumulation and estate planning. In this blog series, we consider the issues in Australian superannuation (retirement) accounts. Many Australians live in the US on E-3, O-1, and EB-2 visas, or as U.S. green card holders, or citizens. These U.S.-based Australians, have likely, accumulated retirement benefits in […]

Tags: Tax Topics, Estate Planning, Blog

FAQ: How to File FBAR?

On behalf of Frost Law posted in on November 6, 2020.

An FBAR must be filed electronically; this can be done through the Financial Crimes Enforcement Network’s BSA E-Filing System. If you are an individual, simply select the “no registration option,” to fulfill your filing obligation. Institutions however must register for the BSA E-Filing System in order to File FBAR. If you would like to paper-file […]

Tags: Blog

A Red Card for Puerto Rico Tax Incentives?

On behalf of Frost Law posted in on November 5, 2020.

Peter Palsen, International Tax Professional In the 2018 book Red Card – How the U.S. Blew the Whistle on the World’s Biggest Sports Scandal, author Ken Bensinger spends 368 pages discussing how the Internal Revenue Services (IRS), Treasury Financial Crimes Enforcement Network (FinCEN) and the Federal Bureau of Investigation (FBI) collectively carried out a cross-border, […]

Tags: Tax Topics, Articles

Former Baltimore Mayor Pugh faces Multiple Charges over Bookgate Scandal

On behalf of Frost Law posted in on May 28, 2020.

Update: As of November 21, 2019, various news sources are reporting that Former Mayor Pugh has pleaded guilty to four of the 11 charges in an executed plea deal. According to these reports, she pleaded guilty to at least one charge of tax evasion. Earlier this year, we reported the first public display of federal […]

Tags: Blog, Tax Evasion, Tax Crimes, IRS

Certain U.S. Individuals Exempted from Tax-Favored Foreign Trust Information Reporting

On behalf of Frost Law posted in on May 1, 2020.

Eli S. Noff, Esq., Partner By now, most Americans with assets abroad understand that the Internal Revenue Service (IRS) expects them to disclose these assets-or risk subjecting themselves to serious penalties for failure to comply. Recently, the IRS has provided significant and welcome relief from reporting requirements for a particular category of assets that were […]

Tags: IRS, Articles

IRS Can Re-litigate Tax Liability in Civil Court After it was Previously Resolved in a Criminal Proceeding

On behalf of Frost Law posted in on May 1, 2020.

Eli S. Noff, Esq., Partner EXECUTIVE SUMMARY The doctrine of collateral estoppel does not bar the IRS’s pursuit of civil tax liability, even where the same liability was previously resolved in a criminal proceeding. Taxpayers should remember that, depending on the circumstances, the Internal Revenue Service (IRS) may successfully pursue and recoup both civil deficiencies […]

Tags: IRS, Articles

Execution of Closing Agreement for Tax Return Preparer Penalties Waived Supervisory Approval Requirement

On behalf of Frost Law posted in on April 30, 2020.

Eli Noff, Esq., Partner Generally, per Internal Revenue Code (IRC) §6751(b)(1), the Internal Revenue Service (IRS) is precluded from assessing a penalty unless the initial determination assessment “is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.” Recently, the Tax […]

Tags: Tax Controversies, Articles

Proposed Regulations Clarify Tax Treatment of Charitable Donations in Return for SALT Credits

On behalf of Frost Law posted in on April 24, 2020.

Eli Noff, Esq., Partner On December 13, 2019, the Internal Revenue Service (IRS) released proposed regulations which provide guidance for businesses and individuals regarding the tax treatment of charitable fund donations made in exchange for state and local tax (SALT) credits. Additionally, the proposed regulations provided guidance regarding the application of the “quid pro quo” […]

Tags: Tax Topics, Articles

Study Analyzes Why People use Offshore Accounts

On behalf of Frost Law posted in on April 24, 2020.

The use of offshore accounts is a point of contention in the media these days. The release of the Paradise Papers and Panama Papers arguably aimed to bring down the reputation of those who used these accounts, but the information may have led to an unforeseen result. Instead of just leading to negative press, the […]

Tags: Blog, IRS