Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Foreign Trust

FATCA FAQ provides guidance on foreign partnership & trust agreements

FATCA FAQ provides guidance on foreign partnership & trust agreements

IRS has recently updated its list of frequently asked questions (FAQs) to provide information on the effective date of an entity’s withholding foreign partnership (WP) or withholding foreign trust (WT) agreement, if the entity submits an application for WP or WT status on or after April 1 and is approved for such status. Click here to view […]

Read the full article →

Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Notice 2015-54, 2015-34 IRB In a Notice, IRS has announced that it intends to issue regs under Code Sec. 721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the […]

Read the full article →

FIRPTA Amendments Proposed To Encourage Foreign Investment In U.S. Real Estate

FIRPTA Amendments Proposed To Encourage Foreign Investment In U.S. Real Estate

Two senior members of the U.S. House Ways & Means Committee, one Republican and one Democrat, have introduced amendments to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) that aim to encourage greater foreign investment in U.S. real estate. Background on FIRPTA. In December of ’80, Congress enacted FIRPTA. It greatly revised the […]

Read the full article →

Final Regs Drop “Timely Form 5472 Even Though Untimely Return” Rule

Final Regs Drop “Timely Form 5472 Even Though Untimely Return” Rule

T.D. 9707, 12/23/2014; Reg. § 1.6038A-1, Reg. § 1.6038A-2, Reg. § 1.6038A-4   IRS has issued final regs that drop the requirement that Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” be timely filed even when the corresponding income tax return is […]

Read the full article →

IRS provides additional time for withholding foreign trusts & partnerships to renew agreements

IRS provides additional time for withholding foreign trusts & partnerships to renew agreements

Click here for “Renewal of Withholding Foreign Partnerships and Withholding Foreign Trusts,” from IRS’s website. On its website, IRS has provided transitional rules for Withholding Foreign Trusts (WTs) and Withholding Foreign Partnerships (WPs) to renew their existing WT and WP agreements, which expire on June 30, 2014. Since IRS has not yet published the revised […]

Read the full article →

Foreign Recipients of US Income Study, 2011 Tax Year

Foreign Recipients of US Income Study, 2011 Tax Year

Two tables presenting data for Tax Year 2011 from Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, are now available here. The tables include statistics for the number of returns, total income, tax withheld, income subject to withholding, income exempt from withholding, and income by category. Data are available by selected countries and […]

Read the full article →

IRS, Australia and United Kingdom Engaged in Cooperative Effort to Combat Offshore Tax Evasion

IRS, Australia and United Kingdom Engaged in Cooperative Effort to Combat Offshore Tax Evasion

The tax administrations from the United States, Australia and the United Kingdom announced a plan to share tax information involving a multitude of trusts and companies holding assets on behalf of residents in jurisdictions throughout the world. The three nations have each acquired a substantial amount of data revealing extensive use of such entities organized […]

Read the full article →

Los Angeles Accountant Pleads Guilty To Tax Crimes Related To Hawaii Clients

Los Angeles Accountant Pleads Guilty To Tax Crimes Related To Hawaii Clients

As reported in the news by the DOJ, Dennis Duban, a Los Angeles-based accountant and tax return preparer, pleaded guilty to conspiracy to defraud the Internal Revenue Service (IRS) and assisting in the filing of a false federal income tax return before U.S. District Court Judge Leslie E. Kobayashi in Honolulu, Hawaii. Duban was previously […]

Read the full article →

IRS Workers With Convictions

IRS Workers With Convictions

Editor’s Note:  after blogging on “Tax Court Alert: Civil Fraud Penalty Assessed Against IRS Tax Compliance Officer,” I came across another article, published some time ago by Forbes entitled “IRS Workers with Convictions,” which reported on the tax agency dealing with rogue employees in everything from celebrity snooping to extortion.  What brought that to mind […]

Read the full article →

Residents of California and Utah Sentenced for Tax Fraud

Residents of California and Utah Sentenced for Tax Fraud

According to the Department of Justice press release on August 13, 2012, David L. Johnson and Michael L. Putnam were sentenced today following their convictions for tax crimes related to their involvement in the Genesis Fund, the Justice Department and Internal Revenue Service (IRS) announced. Both Johnson and Putnam had previously pleaded guilty before U.S. […]

Read the full article →

Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028

Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028

Estate may be liable for increases to decedent’s foreign trust reporting penalties Chief Counsel Advice 201208028 In Chief Counsel Advice (CCA), IRS has determined that, because a decedent failed to file Forms 3520 and 3520-A with respect to a foreign trust he created, his estate became liable to pay Code Sec. 6677 initial and additional […]

Read the full article →

Swiss Bankers Are Afraid To Leave Switzerland – IRS and Department of Justice Making an Impact

Swiss Bankers Are Afraid To Leave Switzerland – IRS and Department of Justice Making an Impact

Editor’s Note:  well, the IRS and Department of Justice enforcement side seems to be doing the job.  I ran across this article entitled “Swiss Bankers are Afraid to Leave Switzerland” as reported in the Huffington Post and found myself chuckling at the thought that Swiss bankers are afraid of being arrested by IRS and DOJ […]

Read the full article →

Three Tax Return Preparers Charged with Helping Clients Evade Taxes by Hiding Millions in Secret Accounts at Two Israeli Banks

Three Tax Return Preparers Charged with Helping Clients Evade Taxes by Hiding Millions in Secret Accounts at Two Israeli Banks

Here in the Central District, U.S. District Court of California, the U.S. Department of Justice announced, in their press release of June 15, 2012, that David Kalai, Nadav Kalai and David Almog were indicted by a federal grand jury in the Central District of California and charged with conspiring to defraud the United States, the […]

Read the full article →

Rand Paul Seeks to Block Tax Treaty Account on Swiss Accounts

Rand Paul Seeks to Block Tax Treaty Account on Swiss Accounts

Editor’s Note:  I read an interesting article entitled “Rand Paul Seeks to Block Tax Treaty Account on Swiss Accounts,” as noted by Bloomberg Businessweek.com.  The article provides a good overview of what has been happening with the exchange of information between the U.S. and Swiss taxing authorities.  We have written many articles and pages on […]

Read the full article →
Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney