| 
On January 25, 2017, the federal court in Montana authorized the IRS to serve John Doe Summons on Michael Berg of Bozeman, Montana, seeking information about US taxpayers with offshore accounts established by Sovereign Management & Legal LTD (“Sovereign”), a Panamanian company. In particular, the IRS is interested in US taxpayers who use debit cards […]
Israel continues to solidify its leading positions in the IT market by using tax policy. On January 1, 2017, Amendment 73 to the Law for the Encouragement of Capital Investments of 1959 entered into force. The main goal of the Amendment is to clarify, extend and improve the Israeli tax breaks for IT companies operating […]
On February 10, 2017, the IRS scored yet another victory in its fight against secret offshore accounts with the imposition of a $100 Million FBAR Penalty. Mr. Dan Horsky, a 71-year old retired university professor (he used to teach at a business school), was a spectacularly successful investor and a very unsuccessful tax evader. After […]
Outbound business tax planning should form part of every outbound business transaction, whether it is in technology transfers, export of goods or an investment overseas. In this article, I would like to discuss the main goal of the outbound business tax planning and identify the overall “global” (i.e. looking at the entire genre of outbound […]
Using proper currency conversion rates is a critical part of preparing 2016 FBAR and 2016 Form 8938. The instructions to both forms require (in case of Form 8938, this is the default choice) US taxpayers to use the 2016 FBAR Currency Conversion Rates published by the Treasury Department. The 2016 FBAR Currency Conversion Rates also […]