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The IRS has established various rules regarding required tax years in order to prevent excess deferral of taxes by partnerships, S corporations, and personal service corporations. In certain circumstances, however, under Internal Revenue Code Section 444, partnerships, S corporations, and personal service corporations may elect to use a tax year other than their required tax […]
A lot of taxpayers are still confused about whether they need an attorney or an accountant to file delinquent Forms 8938. As I explain below, Form 8938 is an essentially legal disclosure form and its voluntary disclosure should be handled by an experienced international tax attorney. Form 8938 Requires Legal Disclosure It is important to […]
For taxpayers with undisclosed offshore accounts and who are looking to do an FBAR voluntary disclosure with the IRS, it is crucially important to understand that FBAR disclosure is a legal issue that should be handled by an international tax attorney. Confusion Over the Roles of Legal and Accounting Professions in FBAR Disclosures I receive […]
The IRS recently released Rev. Proc. 2013-21 detailing the updated price inflation adjustment limitations on depreciation deductions and lease inclusion amounts for passenger automobiles first placed in service during calendar year 2013. These adjustments are required under Internal Revenue Code Section 280F. If you need advice relating to these matters, or any other tax or […]
On March 6, 2013, the IRS issued statistics for the tax year 2008 with respect to foreign corporations controlled by U.S. corporations. These statistics emphasize the important growth in controlled foreign corporations (“CFCs”) and Form 5471. IRS Statistics Published in Statics of Income Bulletin (Winter 2013) In the tax year 2008, some 83,642 foreign corporations […]