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Mexican Fideicomiso is one of the most convenient ways for U.S. persons to purchase land in Mexico. Of course, one can purchase the land through a Mexican corporation, but such an arrangement will require additional tax planning and higher annual compliance costs, including potentially filing form 5471, Form 8938 and other forms. Therefore, most U.S. […]
Recently, there have been signs that the IRS is pondering the future of its flagship Offshore Voluntary Disclosure Program (2014 IRS OVDP): does this means that there is a potential for the 2014 IRS OVDP to end soon? TIGTA Report and 2014 IRS OVDP The latest warning signal came on June 2, 2016. On that […]
Foreign Gift Requirements is one of the most important topics for U.S. taxpayers with foreign relatives. In this article, I would like to quickly overview foreign gift requirements for U.S. tax purposes. Foreign Gift Requirements: What is a Foreign Gift? Legally, the term “gift” means a definite, voluntary and gratuitous transfer of property from one individual to […]
For several years now, Sherayzen Law Office has been warning U.S. taxpayers about the ever-increasing IRS interest in undeclared accounts in Singapore. On June 22, 2016, the IRS announced that UBS AG has complied with the IRS summons for bank records held in its Singapore office. This news come after repeated initiatives by the IRS […]
On June 22, 2016, the IRS and the US DOJ successfully brought to conclusion the Bergantino Case with a guilty plea by Mr. Michele Bergantino (a citizen of Italy and a resident of Switzerland) to charges related to aiding and assisting U.S. taxpayers in evading their income taxes. Mr. Bergantino, a former Credit Suisse AG […]