Reporting Large Foreign Gifts and Inheritances—Internal Revenue Code 6039F, Notice 97-34 & IRS Form 3520, by Frank Agostino, Esq. and Phillip Colasanto, Esq.

As of 2016, over 43 million immigrants resided in the United States (U.S.) (i.e. almost 14% of the population are immigrants). Many immigrants (and their tax professionals) do not think about gift or estate taxes when they receive money or property from their family abroad. Domestic gifts and inheritances are not taxed to the beneficiary of the gift or bequest because the U.S. taxes gratuitous transfers at the source of the transfer (i.e., the donor, grantor, or the estate); nor do domestic gifts impose any reporting requirements on the recipient. Even with respect to the donor, the es- tate and gift tax lifetime exclusions are high enough that many immigrants and their tax pro- fessionals assume the estate and gift tax is some- thing they can ignore. This is a flawed assump- tion, especially regarding foreign gifts that a tax- payer receives while a resident of the United States. …

TAC Tip, by Desa Lazar, Esq.

Due Diligence Checklist to Protect Clients Facing Passport Revocation. 

In the December 2017 edition of the Agostino & Associates Monthly Journal of Tax Controversy, tax professionals were alerted about a new Inter- nal Revenue Service (“IRS” or “Service”) initiative which allows the IRS to certify certain delinquent taxpayers to the State Department for passport revocation(the “Passport Article”).1 As detailed in the article, taxpayers with “seriously delinquent tax debt,” as that term is defined in IRC §7345, are subject to losing their passports (or having applications for new passports denied) unless they get into good standing with the IRS. This TAC-Tip is aimed at providing tax professionals who represent taxpayers potentially subject to this new IRS initiative with a checklist of tools they can use to protect their clients. …

To read these articles and the whole Journal, Click on the image below.

 

 

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