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Cryptocurrency and Compliance with U.S. Federal Tax Laws Are Under Scrutiny

By:  Coleman Jackson, Attorney, Certified Public Accountant February 08, 2018  Cryptocurrency is a virtual currency or digital value that serves as a medium of exchange, amount of wealth or measure of account or value.  Virtual currency may act like a monetary currency, but it is not considered legal tender in the United States or anywhere…

Tax Cuts and Jobs Act from Practicing Tax Professional’s Viewpoint

By Coleman Jackson, Attorney, CPA January 13, 2018 The 2017 Tax Cuts and Jobs Act became law during the closing days of 2017.  This blog will look at these significant tax law changes from the perspective of a practicing tax professional’s point-of- view.  We are not interested in discussing in any details the political, social,…

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U.S. Persons Holding Controlling Interests in Foreign Businesses – The Long Arm of the U.S. Internal Revenue Service

By:  Coleman Jackson, Attorney, CPA December 05, 2017 Pursuant to Internal Revenue Code Section 6038, U.S. persons (this term includes citizens and green card holders of the United States under U.S. Tax Law) holding controlling interest in foreign corporations must annually disclose certain ownership and financial information about the business and the U.S. taxpayer’s interest…

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FACTS MATTER! TAXPAYERS CAN WIN WILLFUL FAILURE TO FILE FBAR CASES IN COURT!

By Coleman Jackson, Attorney, CPA October 20, 2017 Under United States law an annual reporting and disclosure responsibility is placed on any United States person with any financial interest in or signatory authority over, a bank, brokerage, stock, or any other financial account in a foreign country.  See 31 U.S.C. Sec. 5314(a) and regulation 31…

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Withholding Tax Responsibilities of U.S. Domestic & Foreign Partnerships with Foreign Partners

By Coleman Jackson, Attorney, CPA October 05, 2017 Internal Revenue Code Section 1446 imposes a duty on any U.S. domiciled partnership & foreign partnership with taxable income and foreign partners to withhold and turn over to the IRS withholding tax in equal proportion to the taxable income allocable to the foreign partners that is effectively…

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The Reach of the Long-Arm of IRS Collections Overseas

By Coleman Jackson, Attorney, Certified Public Accountant September 01, 2017 The collection arm of the U.S. Internal Revenue Service is extremely long.  This particular blog is limited to that reach as for collecting tax penalties associated with taxpayers who fail to file information returns pertaining to foreign bank accounts and foreign assets.  The basic tax…

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Taxpayer’s Responsibility to Substantiate the Numbers on Their Federal Tax Return

By Coleman Jackson, Attorney and Certified Public Accountant August 08, 2017 As a general rule a taxpayer is allowed a deduction for all ordinary and necessary expenses paid or incurred during the taxable year in carrying on a trade or business.  This basic tax rule is set forth in Internal Revenue Code Section 162.  The…

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Report of Foreign Bank and Financial Accounts

By:  Coleman Jackson, Attorney, CPA July 18, 2017 United States Persons who hold a financial account in a foreign country with a balance anytime during the calendar year of $10,000 or more must file a Report of Foreign Bank and Financial Accounts (FBAR) report.  This disclosure is currently due on April 15th of each year. …

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U.S.A. IMMIGRATION OPTIONS AVAILABLE TO VICTIMS OF DOMESTIC VIOLENCE

By Coleman Jackson, Attorney & Counselor at Law July 12, 2017 There are three ways immigrants who become victims of domestic violence, sexual assault, and some other specific crimes may apply for legal immigration status for themselves and their child(ren). Self-petition for legal status under the Violence Against Women Act (VAWA) Cancellation of removal under…

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Responsible Party Liability for Willfully Failing to Pay Payroll Taxes

June 12, 2017 Coleman Jackson, Attorney, CPA The Internal Revenue Code, 26 U.S.C. § 6672 authorizes the Internal Revenue Service to demand collection of unpaid payroll taxes from persons responsible for paying those taxes if those persons willfully fail to pay the payroll taxes in the normal course of running a business.  This statutory duty…

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WHEN ARE PAYMENTS FOR SERVICES PERFORMED EXCLUDED FROM AN EMPLOYEES GROSS INCOME?

By Coleman Jackson, Attorney, CPA May 30, 2017 The term wages are defined in 26 U.S.C. Sec. 3401 as all remuneration (other than fees paid to a public official) for services performed by an employee for his employer, including the cash value of all remuneration (including benefits) paid in any medium other than cash; except…