Use of John Doe Summons in Foreign Account Cases
Sometimes, the IRS may use a John Doe summons to obtain information about the taxpayer whose international tax liability it is trying to determine.
Sometimes, the IRS may use a John Doe summons to obtain information about the taxpayer whose international tax liability it is trying to determine.
Depending on whether you are a U.S. Citizen or Resident, you have various reporting and disclosure requirements to the IRS on your U.S. source and worldwide income.
If you meet the conditions of the substantial presence test, you are considered to be a U.S. resident for U.S. tax purposes. If you qualify as a U.S. resident under the substantial presence test, you may be able to have your nonresident spouse treated as a U.S.
Over the past few years, the IRS has instituted aggressive rules to force Foreign Financial Institutions (FFIs) and Non-Financial Foreign Entities (NFFEs) to enter into FATCA (Foreign Account Tax Compliance Act) agreements which require compliance with strict reporting requirements on the assets
If you have a U.S. Green Card, you are considered a U.S. resident for tax purposes. Accordingly, you are a lawful permanent resident and are subject to U.S. tax, even on worldwide income.
The streamlined procedures have a different set of requirements depending on whether the taxpayer currently resides within or outside of the United States. If you are eligible to use the Streamlined Foreign Offshore Procedures, then you must follow particular steps.
Some U.S. taxpayers living abroad may be unaware of their international tax duty to file U.S. tax returns and FBAR forms.
In recent months the number of US Department of Justice prosecutions of US persons with international tax problems involving previously unreported foreign income and assets has risen sharply.
Applicants eligible under the Streamlined Foreign Offshore Procedures must follow particular steps to ensure that their returns are processed under the special program.
If you are eligible to use the Streamlined Domestic Offshore Procedures, then you must follow particular steps. If you fail to properly comply with the steps, then your application will be rejected for the streamlined procedures.