New Rules for Investors in Foreign Insurers Proposed by IRS

The IRS recently released rules for investors in foreign insurance companies under tax code section 1297. The document linked to below contains proposed regulations under sections 1291, 1297, and 1298 of the Internal Revenue Code regarding the determination of ownership in a passive foreign investment company within the meaning of section 1297(a) (“PFIC”) and the treatment of certain income received or accrued by a foreign corporation and assets held by a foreign corporation for purposes … Read More

IRS Says Renew ITINs Now

Nearly 2 million Individual Taxpayer Identification Numbers (ITINs) are set to expire at the end of 2019 as the Internal Revenue Service continues to urge affected taxpayers to submit their renewal applications early to avoid refund delays next year. “We urge taxpayers with expiring ITINs to take action and renew the number as soon as possible. Renewing before the end of the year will avoid unnecessary delays related to their refunds,” said IRS Commissioner Chuck … Read More

Northern Michigan Tax Scam

Northern Michigan taxpayers with past-due tax debts should be aware of an aggressive scam making the rounds through the U.S. Postal Service, according to the Michigan Department of Treasury. Recently, an Emmet County taxpayer received what appeared to be an official-looking letter about an overdue tax bill, asking the individual to immediately contact a toll-free number to resolve their outstanding state tax debt. The letter threatened to seize the taxpayer’s assets ― including property, bank … Read More

IRS Beginning to Audit Taxpayers with Cryptocurrency Assets

She also said that SB/SE is coordinating with the agency’s Large Business and International (LB&I) Division in determining how to proceed in cryptocurrency-related audits because more of those cases are cropping up. Murphy also said SB/SE is conducting work related to the Bank Secrecy Act stemming from information the IRS received in its summons on Coinbase Inc., one of the world’s largest cryptocurrency exchanges. That act requires U.S. financial institutions to collaborate with the U.S. … Read More

Crypto Exchanges Facing Global Money Laundering Rules

More than 30 countries will soon need to adopt stricter rules governing cryptocurrency exchanges and transactions or risk falling out of step with new international standards. The Financial Action Task Force, an inter-governmental group focused on money laundering, signed off on guidance June 21 instructing crypto exchanges to gather and transmit more user data. It’s meant to crack down on illicit financial activity by ensuring more details are known about parties on the receiving end … Read More

Tax Cheater’s Kids Get Jail Time

Henry Seggerman’s four children did not report the millions of dollars he hid in offshore bank accounts – and now they are going to jail. They chose to keep the accounts hidden from the Internal Revenue Service, and on June 26 their decision came back to haunt them. Although they spent almost a decade helping prosecutors in a probe of tax evasion, they were sentenced to federal prison. Seggerman, a pioneer of international investing, left … Read More

US Taxpayers Can Claim Refunds for French Social Taxes

The IRS recently announced that U.S. Taxpayers have 10 years to file for refunds of “social taxes” they paid on income earned in France over the past decade. The 10-year period for filing a claim begins the day after the regular due date for filing the return for the year to which the foreign taxes relate, the IRS said in a statement. If you have paid Social Taxes – also known as CSG or CRDS … Read More

Guidance Related to Global Intangible Low Taxed Income

The Document linked to below contains proposed regulations implementing section 951A of the Internal Revenue Code. Section 951A was added to the Internal Revenue Code by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document also contains proposed regulations under sections 951, 1502, and 6038. These proposed regulations would affect United States shareholders of controlled foreign corporations. This document contains proposed amendments to 26 CFR part 1 under sections … Read More