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May 24, 20222 min read
Late QEF Election Granted to Married Couple Unaware of PFIC Status (PLR 202220014, February 2, 2022)
Taxpayers filed their U.S. federal income tax returns as a married couple filing jointly for the 5 years relevant to this letter ruling....
Feb 24, 20221 min read
2022 Update to the Form 14457, Voluntary Disclosure Practice Preclearance Request
On February 15, 2022, the IRS announced an update to the Form 14457, 'Voluntary Disclosure Practice Preclearance Request'. Noncompliance...
Mar 9, 20214 min read
Options for Noncompliance with US Foreign Reporting Obligations
Noncompliance with foreign reporting obligations such as the FBAR and the Form 8938 ‘Statement of Foreign Financial Assets’ can result in...
Feb 16, 20213 min read
Penalties for Non-willful Violations of FBAR Filings must be Assessed on a Per Form Basis
Kaufmann had 13 foreign accounts in Israel that were not reported on the Form TD F 90-22.1, "Report of Foreign Bank and Financial...
Feb 16, 20212 min read
Don't Forget to Report Foreign Gifts and Inheritances
Gifting can be a great way to move appreciated assets out of your estate, transfer income to lower taxed family members or just to be...
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