Thursday, March 31, 2016

Tax On Late-Filed Forms Not Dischargeable in Bankruptcy!

According to Law360, the Eleventh Circuit said Wednesday that an individual's tax debts were not dischargeable in bankruptcy because his tax returns were filed after the due date and thus do not constitute an honest and reasonable attempt to satisfy the requirements of the tax law.

The appellate court said it joined with the Fourth, Sixth, Seventh and Ninth Circuits in finding that delinquent tax returns fail the fourth prong of the so-called Beard test, which determines if a tax return is valid for purposes of discharging tax debts in bankruptcy.

"Failure to file a timely return, at least without a legitimate excuse or explanation, evinces the lack of a reasonable effort to comply with the law," Judge R. Lanier Anderson said in the court's unpublished opinion.

Have a Tax Problem?
Contact the Tax Lawyers at
Marini & Associates, P.A.
 for a FREE Tax Consultation Contact US at 
or Toll Free at 888-8TaxAid (888 882-9243).


Wednesday, March 30, 2016

The IRS Now Has Six Years To Audit Your Taxes!

Beware: IRS Now Has Six Years To Audit Your Taxes, Up From Three preview image

Forbes has an article Beware: IRS Now Has Six Years To Audit Your Taxes, Up From Three which discussed that no one wants to be audited, so knowing how long your tax return can be attacked is important.

The statute of limitations on taxes is a fundamental rule allowing taxpayers to eventually cut off their exposure. It can be pretty satisfying to say to the IRS, “sorry, you’re too late.” But this year, that will be a little harder due to an expansion of the IRS’s power to audit for extra years.

Six years can be a long time. Filing your return early won’t help either.

The time periods can be even longer than six years in some cases. The IRS has no time limit if you never file a return. For unfiled tax returns, criminal violations or fraud, though, the practical limit is usually six years.

Another scary rule is that the IRS can audit forever if you omit certain tax forms. Plus, once an assessment is made, the IRS collection statute is typically 10 years.

In some cases, the IRS can go back 30 years. In Beeler v. Commissioner, the Tax Court held Mr. Beeler responsible for 30 year-old payroll tax penalties. Click Here To Read More...

Have a Tax Problem?
Contact the Tax Lawyers at
Marini & Associates, P.A.
 for a FREE Tax Consultation Contact US at 
or Toll Free at 888-8TaxAid (888 882-9243).


IRS Revises Offer in Compromise Booklet and Application

The 2016 revision to Offer in Compromise Booklet Form 656-B will is available for download. The booklet contains necessary forms and instructions for submitting an Offer in Compromise. Use of earlier versions may result in a delay in the processing of Offer applications.

An offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can't pay your full tax liability, or doing so creates a financial hardship. The IRS considers your unique set of facts and circumstances including:
  • Ability to pay;
  • Income;
  • Expenses; and
  • Asset equity.
The IRS generally will approve an offer in compromise when the amount offered represents the most that the IRS can expect to collect within a reasonable period of time. Explore all other payment options before submitting an offer in compromise. The Offer in Compromise program is not for everyone.

The IRS reminds Taxpayers
that if they hire a Tax Professional
to help them file an Offer in Compromise,
Be Sure to Check their Qualifications!

Make sure you are eligible

Before the IRS can consider your offer, you must be current with all filing and payment requirements. You are not eligible if you are in an open bankruptcy proceeding. Use the Offer in Compromise Pre-Qualifier to confirm your eligibility and prepare a preliminary proposal.

the IRS is in the process of making modifications to the Pre-Qualifier Tool application. If you use this tool, please consider making the following adjustments to your displayed results.
  • If you enter an amount on Screen 3 Assets, Line 1 which reads "Total bank Balances," you may reduce this amount by $1000. The result may not be less than zero.
  • If you enter an amount on Screen 3, Vehicle 1, you may reduce this amount by $3450. The result may not be less than zero.
  • If you enter an amount on Screen 3, Vehicle 2, and you are making a joint offer with a spouse or other party, you may also reduce this amount by $3450. The result may not be less than zero.  

Submit your offer

Your completed offer package will include:
  • Form 433-A (OIC) (individuals) or 433-B (OIC) (businesses) and all required documentation as specified on the forms;
  • Form 656(s) - individual and business tax debt (Corporation/ LLC/ Partnership) must be submitted on separate Form 656;
  • $186 application fee (non-refundable); and
  • Initial payment (non-refundable) for each Form 656.

Select a payment option

Your initial payment will vary based on your offer and the payment option you choose:
  • Lump Sum Cash: Submit an initial payment of 20 percent of the total offer amount with your application. Wait for written acceptance, then pay the remaining balance of the offer in five or fewer payments.
  • Periodic Payment: Submit your initial payment with your application. Continue to pay the remaining balance in monthly installments while the IRS considers your offer. If accepted, continue to pay monthly until it is paid in full.
If you meet the Low Income Certification guidelines, you do not have to send the application fee or the initial payment and you will not need to make monthly installments during the evaluation of your offer. See your application package for details.

Understand the process

While your offer is being evaluated:
  • Your non-refundable payments and fees will be applied to the tax liability (you may designate payments to a specific tax year and tax debt);
  • A Notice of Federal Tax Lien may be filed;
  • Other collection activities are suspended;
  • The legal assessment and collection period is extended;
  • Make all required payments associated with your offer;
  • You are not required to make payments on an existing installment agreement; and
  • Your offer is automatically accepted if the IRS does not make a determination within two years of the IRS receipt date.
If your offer is acceptedIf your offer is rejected
  • You must meet all the Offer Terms listed in Section 8 of Form 656, including filing all required tax returns and making all payments;
  • Any refunds due within the calendar year in which your offer is accepted will be applied to your tax debt;
  • Federal tax liens are not released until your offer terms are satisfied; and
  • Certain offer information is available for public review at designated IRS offices.
  • You may appeal a rejection within 30 days using Request for Appeal of Offer in Compromise, Form 13711 (PDF).

Have a Tax Problem?

 Want to Know if you Qualify for an Offer?

Contact the Tax Lawyers at
Marini & Associates, P.A.
 for a FREE Tax Consultation Contact US at 
or Toll Free at 888-8TaxAid (888 882-9243).


Surrendering Green Card Not Expatriation For Tax Purposes?

A German citizen who expatriated to Germany in 2010 was found to owe taxes on stock installment sale payments, after he formally abandoned his lawful permanent resident status for immigration purposes. (Topsnik v. Commissioner, 146 T.C. No. 1 (2016))

In 2010, he received installment payments from his 2004 sale of his stock in Gourmet Foods Inc. a business he started in the 1980s. Topsnik argued that his date of expatriation was Dec. 31, 2009 and that he did not owe taxes in 2010, but the court found that the actual date of his expatriation was Nov. 20, 2010, the day he gave up his green card.

“We find that petitioner was not a ‘resident’ of Germany in 2010 as defined by article 4, paragraph 1, of the U.S.-Germany tax treaty,” Judge Kathleen Kerrigan said in the court’s opinion. “Accordingly, petitioner’s monthly installment payments were taxable by the United States.”

Topsnik had argued that he was a German resident in 2010 because he owned a hotel there and had access to one of its rooms, but he presented no proof of ownership, the court said.

The German Competent Authority also had no record that Topsnik had a registered residence or habitual abode in Germany that year. Furthermore, he was registered as a nonresident for tax purposes in Germany in 2010, so he cannot claim to be a German resident under the U.S.-Germany tax treaty, the court said, granting summary judgment to the Internal Revenue Service.
The taxpayer also did not file a Form 8854 when he surrendered his green card and he had not fully complied with required filings for the preceding five years. Such failure to certify effectively makes him a covered expatriate (Code Section 877(a)(2)(C), which is part of the definition of a covered expatriate under Code Section 877A(g)(1)). So it appears that failing to certify was enough to be a covered expatriate.

This case also demonstrates that the deemed sale of assets rule of Code Section 877A, which applies to expatriates, triggers the deferred gain on an installment sale obligation held by the expatriate under Code Section 453B; with the deemed selling of the price of the obligation being its face amount.
This decision triggered an information letter from the Office of the Chief Counsel on the taxation of green card holders. The court decision went against the taxpayer when the court held that a resident alien who is lawfully present in the US can not just informally abandon their residency. The information letter covers the tax rules applicable to green card holders including first-year residency, no lapse residence rules, dual residency, application of tax treaties, terminating residency and expatriation.
You are a “Covered Expatriate” if you are a Long-Term Resident, as defined in IRC 7701(b)(6),and you cease to be a lawful permanent resident because:
  1. The individual’s status of having been lawfully accorded the privilege of residing permanently in the United States as an immigrant in accordance with immigration laws has been revoked or has been administratively or judicially determined to have been abandoned, or 
  2. The individual:
(1) Commences to be treated as a resident of a foreign country under the provisions of a tax treaty between the United States and the foreign country,
(2) Does not waive the benefits of the treaty applicable to residents of the foreign country, and(3) Notifies the IRS of such treatment on Forms 8833 and 8854.

Form 8854, Initial and Annual Expatriation Information Statement and its Instructions have been revised to permit individuals to meet the new notification and information reporting requirements. 

The revised Form 8854 and its instructions also address how individuals should certify (in accordance with the new law) that they have met their federal tax obligations for the five preceding taxable years and what constitutes notification to the Department of State or the Department of Homeland Security.
"Should I Stay or Should I Go?"

Need Advise on Expatriation ... 

Contact the Tax Lawyers of 
Marini& Associates, P.A.   
For a FREE Tax Consultation at: or or
Toll Free at 888-8TaxAid ((888) 882-9243)

Tuesday, March 29, 2016

FinCEN's Luxury Real Estate Reporting Rules - Exceptions!

On February 1, 2016 we posted US Real Estate Investments & Anonymous Entities Again in Spotlight for US Money Laundering!, where we discussed that the Financial Crimes Enforcement Network (FinCEN) on January 13, 2016 issued a Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay "all cash" for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.

The Treasury’s program will affect billions of dollars in real estate transactions. In Manhattan, the initiative requires buyers in sales of more than $3 million to be reported; in Miami-Dade County, it requires reporting on sales of more than $1 million. In Manhattan, 1,045 residential sales cost more than $3 million in the second half of 2015, worth some $6.5 billion in aggregate, according to PropertyShark, a real estate data company.
The key findings from the investigation are:
  • Lawyers from 12 of the 13 firms we visited suggested using anonymous companies or trusts to hide the minister’s assets. All but one of these firms recommended using American companies.
  • One of the lawyers was the President of the American Bar Association at the time.
  • Several lawyers suggested using their law firms’ own bank accounts to help prevent U.S. banks realizing whose money it really was, or to have the lawyer act as a trustee of an offshore trust and use this position to open a bank account.
  • While most of the lawyers asked for some information about the minister, and his source of funds, only one lawyer refused to provide assistance during the meeting itself.
The regulations implementing this new procedure
which went into effect on March 1, 2016
apply to real estate transactions exceeding:
$3 million in New York City
and $1 million in Miami.

According to Law360, loopholes continue to allow sophisticated individuals to sidestep the attention of regulators.

Title Insurance Companies

The new rules, for example, limit the reporting requirements to Title Insurance Companies. Title insurance is usually required by a lender, typically a bank providing a mortgage, for protection against risks originating from flaws in the real property's title. Purchases completed without outside lenders, however, generally negate the need for title insurance and therefore eliminate the only party, a title insurance company, required to report the transaction.

The GTOs, however, specifically target purchases made without a bank loan or other similar forms of financing. In other words, by exempting those transactions that would most likely include title insurance, FinCEN has exempted from its reporting requirements most transactions likely to involve a title insurer, the rule’s mandated reporter.


Another category of transactions exempt from the reporting requirements are those involving a mortgage. Admittedly, FinCEN drafted the new rules in an effort to track what it perceives to be potentially the highest-risk category of real estate purchases: all-cash transactions. If an individual or an entity, including a limited liability company, finances the deal with a small mortgage, the transaction is exempt from the rules' disclosure requirements.

25% Ownership

The FinCEN rules require title insurance companies to identify the beneficial owners, defined as “each individual who, directly or indirectly, owns 25 percent or more of the equity interests” of the legal entity purchasing the real estate. This definition leaves the door open for buyers who splinter their ownership among multiple individuals, such as family members or attorneys, to avoid the 25 percent regulatory threshold.

Offshore Trusts or Foundations

Similarly, beneficial owners could utilize offshore trusts or foundations to benefit an individual, the trust's beneficiary, without conferring the legal status of "owner." These offshore entities are targeted frequently by financial regulators, which have long recognized that individuals have used these vehicles to conceal the origin of illegal proceeds. In using a nominee to control the funds of a trust or foundation, a beneficial owner is able to shield his or her identity from the scrutiny of regulators. Foreign bank secrecy laws barring and even criminalizing disclosure of banking information likewise serve to assist in the concealment.

Wire Transfers

Real estate purchases funded solely through wire transfers also may sidestep the reporting requirements. The FinCEN rules are triggered by purchases made using currency, a cashier’s check, a certified check, a traveler’s check, or a money order. Payment of the purchase price through a wire transfer therefore serves to exempt a transaction from the rules’ requirements. It should be noted that regulators have already targeted lackluster due diligence efforts in connection with foreign transfers. In the last several years, HSBC and Commerzbank have paid combined penalties in excess of $750 million partly for failing to properly scrutinize wire transfers.

The loopholes in these rules, allow sophisticated real estate purchasers to continue buying in these areas largely unimpeded. A savvy financier could easily navigate these rules to circumvent their purpose of curtailing the flow of dirty money.

The rules are timed to expire in August, 2016. However FinCEN may be using the next six months to gather information and assess the efficacy of the measures. In other words, after studying the loopholes and other shortcomings to the rule, FinCEN may reissue or even expand the rules, shoring up the present regulatory gaps.
Need Experience Legal Advice for
Your US Real Estate Investments?

 Contact the Tax Lawyers at 
Marini & Associates, P.A.

for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888)882-9243.


Wednesday, March 16, 2016

Budget Cuts to IRS Business Cause Audits to Plummet!

Preview of the share imageThe Internal Revenue Service’s audits of business tax returns have declined steeply in recent years, thanks to successive rounds of budget cuts, according to a new analysis.

Syracuse University’s Transactional Records Access Clearinghouse, or TRAC, analyzed the IRS’s records from fiscal year 2010 through fiscal year 2015 and found revenue agent hours aimed at corporations with $250 million or more in assets have declined 34 percent, while unreported taxes uncovered by IRS that would otherwise have been lost to the government dropped 64 percent.

The declines were even steeper for the largest corporations, those with $20 billion or more in assets. 

Even more recent data through February of 2016 indicate that business audits of large companies are running 22 percent lower this year than for the same period last year.

To

Have a Tax Problem?

Contact the Tax Lawyers at
Marini & Associates, P.A.
 for a FREE Tax Consultation Contact US at 
or Toll Free at 888-8TaxAid (888 882-9243).

What to do When You Receive an IRS Notice?

The IRS  sends many, many, many, letters and correspondence before they levy or garnished any Taxpayer's wages, bank accounts, or other assets. Many taxpayers take the ostrich approach and ignore the problem, in hopes that it will go away.

If you’re facing an IRS Problem, appropriate action can go a long way towards resolving it!
1. Respond Quickly to All Inquiries and Notices
The IRS will send a notice or letter if:
  • You have a balance due.
  • You are due a larger or smaller refund.
  • They have a question about your tax return.
  • They need to verify your identity.
  • They need additional information.
  • They changed your return.
  • They are notifying you of delays in processing your return.
2. Read the Entire Notice or Letter Carefully.

Typically, the IRS only needs a response if you don’t agree with the information, the IRS needs additional information, or you have a balance due. If the IRS changed your tax return, compare the information the IRS provided in the Notice or Letter with the information in your original return. If the IRS receives a return that they suspect is identity theft, the IRS will ask you to verify your identity using the web address provided in the letter.

When you get a notice in the mail from the IRS, it will have a file/case/claim or other reference
number on the document. You’ll also notice the document likely arrived days (or weeks) later
than the date on the letter/notice.

3. Contact the IRS if You Have Questions or Disagree With the Notice.

The IRS provides their contact phone number on the top right-hand corner of their correspondence.
Call the that phone number as soon as possible upon receipt of the notice to make certain the IRS is aware you are “pending action.” Be sure you have your tax return and any related documentation available when you call. Alternatively, you can write to the IRS at the address in the correspondence to explain why you disagree. If you write, allow at least 30 days for their response.

4. Respond Within the Required Time Frame.
If the IRS ask for a response within a specific time frame, you must respond on time to minimize additional interest and penalty charges or to preserve your appeal rights if you don’t agree.

5. Document all communications with the IRS

If you mail communications to the IRS, send them as certified mail to guarantee arrival and receipt. If you communicate with the IRS by telephone, the responding agent will give you his/her name and ID
number. Be certain to write it down along with the date/time/subject of your call and any answers or information the agent provides. If you do not get a name and ID number, be sure to ask and/or confirm before the end of your call. That way if there are any disputes, there is a record of your communications.

6. Turn Over the Right Paperwork

Inexperienced taxpayers often think that the more paperwork they turn over, the better. The IRS
may even encourage this by stating that they can help you resolve your tax problem. While this may be true, IRS Revenue Agents can and often do make additional adjustments based upon the information and paper work which you supply. Only provide the information that is needed to resolve the problem at hand, not that which may open up a whole new set of problems.

6. Contacting an Experience Tax Attorney Can Help

When you respond quickly to notices and requests for information, you’re likely to find that the
situation can be resolved successfully on your own. But when audits or multiple issues arise, it is advisable to have an Experienced Tax Attorney on your side. 

When you have IRS tax problems, it is very important to handle them very carefully. IRS tax matters are very technical and sensitive; therefore a slight mistake in the process can cost you dearly in the form of loss of money, loss of time and general frustration. The tax laws and procedures involved in settling  your IRS taxes can be very complex and you may not completely understand it.

Dealing with IRS involves navigating the complicated maze of U.S. tax law. A Tax Attorney has the knowledge of tax law and expertise needed to negotiate with the IRS on your behalf to reduce Tax debt & IRS Problems.

The Internal Revenue Service has an army of employees and tax attorneys representing them

and as a taxpayer, you should have the same benefits which result from hiring an Experienced Tax Attorney to represent You, your Business & your Family.

Have a Tax Problem?

Contact the Tax Lawyers at
Marini & Associates, P.A.

 for a FREE Tax Consultation Contact US at 

or Toll Free at 888-8TaxAid (888 882-9243).

Tax Court Holds That FBAR Penalties Aren't Included in $2 million Whistleblower Threshold.

The Tax Court has concluded, Whistleblower 22716-13W, (2016) 146 TC No. 6, that penalties for failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (Foreign Bank Account Report or FBAR) under 31 U.S.C. sec. 5321(a) are not “additional amounts” for purposes of the $2,000,000 nondiscretionary award threshold under Code Sec. 7623(b)(5)(B). Accordingly, FBAR payments must be excluded in determining whether the $2,000,000 amount in dispute requirement has been satisfied. Whistleblower 22716-13W, (2016) 146 TC No. 6.

Under Code Sec. 7623(a), IRS has discretionary authority to pay awards to informants/Whistleblowers the sums it considers necessary for the detection of tax underpayments, or for the detection, trial, and punishment of tax law violators.

Under Code Sec. 7623(b), individuals are entitled to receive an award of 15% to 30% (or lower amounts in cases of less substantial contribution) of the collected proceeds resulting from an action based on information provided by the whistleblower in any action:
  • . . . against any taxpayer, but in the case of any individual taxpayer, only if such individual's gross income exceeds $200,000 for any tax year subject to such action, (Code Sec. 7623(b)(5)(A)) and
  • . . . if the tax, penalties, interest, additions to tax, and additional amounts in dispute exceed $2 million. (Code Sec. 7623(b)(5)(B))
Therefore, a whistleblower is eligible for a nondiscretionary award under Code Sec. 7623(b) only “if the tax, penalties, interest, additions to tax, and additional amounts in dispute exceed $2,000,000.”

The Whistleblower ("WB") filed Form 211, Application for Award for Original Information, with the IRS Whistleblower Office (Office). On the application, "WB" asserted that he was cooperating with the Department of Justice and the IRS Criminal Investigation Division in connection with the ongoing investigation of two Swiss bankers, Martin Lack and Renzo Gadola, and that his cooperation had led to, and would lead to more, information about these bankers' involvement in tax evasion by U.S. persons having undeclared offshore financial accounts.

"WB" filed another claim for an award after he learned that a taxpayer who dealt with Gadola had agreed to pay a substantial penalty in conjunction with a guilty plea for filing a false tax return, an FBAR penalty substantially in excess of $2,000,000, and restitution. This taxpayer admitted that Gadola had helped him open Swiss bank accounts to conceal his income and assets from U.S. authorities.

"WB" claimed entitlement to an award based upon the aggregate amount paid by the taxpayer, including the FBAR penalty, given his alleged involvement in Gadola's arrest, which allegedly led to the taxpayer's arrest.

The IRS informed "WB" that it had received a legal opinion from the IRS Office of Chief Counsel concluding that FBAR penalty payments, because they are made pursuant to Title 31 rather than Title 26 of the U.S. Code, are not collected proceeds eligible for a nondiscretionary award under Code Sec. 7623(b)(1).

The Tax Court held that the term “additional amounts” as used in Code Sec. 7623(b)(5)(B) means the civil penalties set out in chapter 68, subchapter A, of the Internal Revenue Code, captioned “Additions to the Tax and Additional Amounts.” Rejecting the argument that the term “additional amounts” as used in Code Sec. 7623(b)(5)(B) means, “other sums of money,” the Court noted that it has consistently held that “additional amounts,” particularly when it appears in a series that also includes “tax” and “additions to tax,”  is a term of art that refers exclusively to the civil penalties enumerated in chapter 68, subchapter A.

Accordingly, the Tax Court concluded that FBAR civil penalties aren't “additional amounts” within the meaning of Code Sec. 7623(b)(5)(B). Such amounts aren't “assessed, collected...[or] paid in the same manner as taxes” under Code Sec. 6665(a)(1). As a result, FBAR payments must be excluded in determining whether the $2,000,000 amount in dispute requirement has been satisfied.

Want a Reward of Between 15- 30% of Underpaid IRS Tax Liabilities for
Blowing the Whistle on a Tax Cheat?

Contact the Tax Lawyers at
Marini & Associates, P.A.

for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).


Foreign Account Filings Top 1 Million - Know Your Filing Requirements!

Strong and sustained growth of taxpayers complying with foreign financial account reporting reflects improving awareness and compliance of this important part of offshore tax rules, the Internal Revenue Service said today.

Many U.S. taxpayers with foreign accounts exceeding certain thresholds must file Form 114, Report of Foreign Bank and Financial Accounts, known as the "FBAR." It is filed electronically with the Treasury Department's Financial Crimes Enforcement Network (FinCen).

In 2015, FinCen received a record high 1,163,229 FBARs, up more than 8 percent from the prior year. In fact, FBAR filings have grown on average by 17 percent per year during the last five years, according to FinCen data.

Filings of IRS Form 8938, Statement of Specified Foreign Financial Assets, are another sign of growing awareness of foreign reporting requirements. Taxpayers filed more than 300,000 Forms 8938 with their tax returns for tax year 2014, roughly the same as the prior year and up from about 200,000 for tax year 2011, the first year of the form.

Form 8938 resulted from the Foreign Account Tax Compliance Act, known as "FATCA." The filing thresholds are much higher for this form than for the FBAR.

Filing Requirements

Taxpayers with an interest in, or signature or other authority over, foreign financial accounts whose aggregate value exceeded $10,000 at any time during 2015 must file FBARs. It is due by June 30 and must be filed electronically through the BSA E-Filing System website.

Generally, U.S. citizens, resident aliens and certain non-resident aliens must report specified foreign financial assets on Form 8938 if the aggregate value of those assets exceeds certain thresholds. Reporting thresholds vary based on whether a taxpayer files a joint income tax return or lives abroad. The lowest reporting threshold for Form 8938 is $50,000 but varies by taxpayer. See the form's instructions for more information.

The International Taxpayers page on is packed with information. The web site also features a directory that includes overseas tax preparers.

International taxpayers will find the online IRS Tax Map and the International Tax Topic Index to be valuable sources of answers. The IRS also has videos to assist international taxpayers. See IR-2016-03 for more.

By law, Americans living abroad, as well as many non-U.S. citizens, must file a U.S. income tax return. In addition, key tax benefits, such as the foreign earned income exclusion, are only available to those who file U.S. returns.

The law requires U.S. citizens and resident aliens to report worldwide income, including income from foreign trusts and foreign bank and securities accounts. In most cases, affected taxpayers need to complete and attach Schedule B to their tax return. Part III of Schedule B asks about the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located.

More information on the tax rules that apply to U.S. citizens and resident aliens living abroad can be found in, Publication 54, Tax Guide for U.S. Citizens and Resident A

 Have A Tax Reporting Problem?  
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888 882-9243).