Streamlined Filing Compliance Procedures: SFCP 2023 Guide
The Streamlined Filing Compliance Procedures (SFCP) is one of the more popular offshore disclosure programs that the Internal Revenue Service offers…
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LB&I Practice Unit for FBAR (FinCEN 114 Filing Guide) 2023
Several times a year, the Internal Revenue Service publishes Practice Units to assist IRS staff with understanding the application of rules…
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Section 965: Treatment of Deferred Foreign Income (Transition Tax)
Section 965 of the Internal Revenue Code deals with the treatment of deferred foreign income for certain foreign corporations. The Section 965…
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Voluntary Disclosure (Which Foreign Asset Reporting Program is Right For You?)
When a US Person has foreign assets that they did not properly disclose to the Internal Revenue Service and FinCEN, they are considered to be out of…
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Can I Transition From Voluntary Disclosure Program to Streamlined Procedures?
When it comes to making an IRS Offshore Voluntary Offshore Disclosure of previously unreported foreign accounts, assets, investments, and income, the…
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