International Reporting Failures Create Penalty and Statute of Limitations Problems

An ever-growing number of businesses and individuals are going global. Familiarity with the U.S. tax forms that are necessary to properly disclose foreign assets and interests is thus paramount. Four critical forms – Foreign Bank Accounting Re-port (FBAR), 8938, 8621, and 3520 – are summarized, including applicable penalties. K&D associate, Patrick […] Read more »

FBAR Penalty Assessment and Enforcement

FBAR

  K&D associate, Patrick J. McCormick, authored the below article, “FBAR Penalty Assessment and Enforcement“. This article, published here with permission, will appear in the July 2017 issue of the Journal of International Taxation (Thomson Reuters/Checkpoint). Mr. McCormick specializes in the areas of international tax and tax compliance.   Introduction […] Read more »

Key Estate Planning Concepts for International Clients

Estate Planning International Clients

K&D associate, Patrick J. McCormick, authored the below article, “Key Estate Planning Concepts for International Clients”, which will appear in the forthcoming June 2017 issue of Estate Planning, a nationally recognized journal published by Thomson Reuters, and again in a Summer 2017 issue of the Journal of International Taxation, also published […] Read more »

PODCAST: When Civil Tax Cases Become Criminal

  K&D associate, Patrick J. McCormick recently recorded a podcast, “When Civil Tax Cases Become Criminal“, with the Pennsylvania Institute of Certified Public Accountants on basics of criminal tax exposure. From the PICPA website: “Civil tax failures that elevate to criminal tax exposure is a scary thought for CPA practitioners. […] Read more »

IRS Releases Notice 2016-66 To Further Contest Small Captive Structures

Estimated Read Time: 3.1 minutes. On November 1, 2016, the Internal Revenue Service released Notice 2016-66, identifying “micro-captive transactions” (including certain small captive insurance companies) as transactions of interest.  Involvement in such transactions can, under Treas. Reg. § 1.6011-4, necessitate heightened reporting requirements, both for participants and for their advisors.  […] Read more »