Disclaimer: If you are in doubt about pre-paying a 2018 property tax assessment in 2017 or any other legal matter, please consult with an attorney or tax adviser. This article is not intended to substitute for legal advice. The Tax Cuts and Jobs Act recently passed by Congress and signed in to law has already ... [Read more]

Ten years ago, in Yekaterinburg, Russia, on a dark and cold evening, two attorneys in a small office with wooden floors and funny wallpaper on the walls were looking with excitement at their company’s state registration certificate that they had just received. Then they picked up the phone and called their U.S. business partner to ... [Read more]

Happy Earth Day to all the beautiful Children of Earth! Sometimes we fuss and worry about the little things – and forget about how privileged we are to live on such a magnificent planet and be able to call it home. Remember it, be happy, and always love and protect your Mother Earth!

Today is March 8th, the International Women’s Day. We would like to wish all the wonderful women of this wonderful world to have all the happiness, love, and success that they deserve! You have a superpower – an ability to give life. Without you, this world would not be. You can do anything that you ... [Read more]

Back in April of 2016, I predicted that the Panama Papers leak would eventually lead to the U.S. Treasury Department and Internal Revenue Service (IRS) modifying the offshore disclosure programs in effect today [Fn1]. The leak from Panama Papers law firm Mossack Fonesca basically gives an offshore asset roadmap to the IRS and it is a good bet that the U.S. Government either has or will soon obtain a copy of the documents.
AS most tax professionals working with international assets know, the U.S. has very harsh offshore disclosure requirements. The Foreign Bank Account Report (FBAR) requires reporting of all foreign bank accounts over $10,000 in aggregate value. FBAR requirements have existed since the 1980s. More recently, Congress implemented the Foreign Account Tax Compliance Act (FATCA) which requires a myriad of disclosures for various foreign assets. Penalties for merely failing to file can be draconian.