Foreign Business Information Reporting
Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.
Foreign Business Information Reporting
Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.
We represent individuals and businesses with foreign business interests, trusts and investment interests. U.S. tax law requires substantial information reporting for foreign corporations, partnerships, trusts and certain foreign investments. There are substantial penalties for failing to timely report these interests or transactions with these foreign entities on the proper information return. It is critical to properly identify the appropriate filing requirements and ensure they are met for all years.
Latest News
Recent Tax Court Ruling Limits Statute of Limitations for Foreign Account Reporting
By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his ...
Read moreIRS Offshore Voluntary Disclosure Program Will End on September 28, 2018
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency ...
Read moreFBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the ...
Read moreIRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria
By: Heather L. Marello, Esq. In the wake of recent hurricanes that devastated Puerto Rico and the U.S. Virgin Islands, IRS released Notice 2017-56, Physical Presence of Certain Individuals in the Commonwealth of Puerto Rico or ...
Read moreIRS Delinquent 1120F Campaign – Are You Prepared?
By: Lou Carlow The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance. This campaign sends a clear message to foreign businesses with a U.S. business ...
Read moreHow U.S. Foreign Information Reporting applies to Your Cross Border Holdings
By: Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S. Failing to file necessary information returns or ...
Read moreAndreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal ...
Read moreLaw Creates New Due Dates for FBAR and Other Tax and Informational Returns
By: Heather Schmidt On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law. In addition to temporarily extending funding for ...
Read moreTaxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report
By: Heather L. Schmidt To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to annually file a Report of Foreign ...
Read moreFederal Court Approves U.S. Government Issuance Of John Doe Summonses
By: Michael J. Tedesco A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the services of Sovereign Management ...
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Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.