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Immigrant Tax Planning | Permanent Resident vs. Tax Resident

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Canadian Immigrants – Do You Have to Pay Canadian Taxes on Your Worldwide Income?

Immigrants to Canada are given a permanent resident status so as to have the legal right to live, work or study anywhere in Canada. Immigrants need to meet Canadian residency requirements in order to keep their permanent resident status.  There is a misnomer that immigrants in fulfilling their Canadian residency requirements as permanent residents of Canada should also be residents of Canada for tax purposes.  As explained below, the permanent resident requirements are different from the tax resident requirements.  Thus, in reality, it is possible for permanent residents not to become tax residents of Canada while maintaining their legal status as permanent residents in Canada. Read More

Think You Can Hide From The IRS? Target San Diego County, California

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The IRS is using its extensive Big Data resources to pin-point their investigations to the wealthiest areas in San Diego County, California. The idea being that anyone who is selected for investigation in these areas will result in a higher tax liability than those who live in less affluent areas. The government is looking for non-filers, persons engaged in on-line and virtual currency transactions, businesses cheating or delinquent on employment taxes and individuals with undisclosed foreign bank accounts.


When a taxpayer does not file and the IRS has information statements indicating a filing requirement, the IRS uses the data to file a return on behalf of the taxpayer if there is a projected balance owed. In 2012, the IRS used information statements to file 803,000 Read More

Tax Consequences For Foreign Students…Think F, J Visas

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My husband and I chartered a course ourselves long ago in the stormy waters of visas, tax treaties and tax consequences. Considering taxes have just got even more complicated, so its no surprise that I field quite a lot of questions from various visa holders especially foreign students on F-1 visas. Suffice to say that the range of information for foreign students is too much to cover in one blog post, so I will focus on the main points. If you need any more information, you know where to reach me!

If you are a foreign student, you already know from your university that you are one of those who are subject to special rules with respect to the taxation of your income. Usually a foreign student is on an F, J, M, or Q visa. Read More

Sovereign Management In Panama Now Under DOJ/IRS Investigation

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Important announcement to U.S. taxpayers that opened offshore bank accounts through a company called Sovereign Management & Legal, Ltd. Based in Panama, the company offers to help Americans open offshore bank accounts with nominee corporations. Knowing that many people who do take these actions are also committing tax evasion, the IRS and Justice Department obtained a John Doe summons from a federal judge. The IRS hopes to find Americans who used Sovereign to open accounts.

Federal Court Approves U.S. Government Issuance Of John Doe Summonses

A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons to several entities in the U.S who utilized the services of Read More

Walking The Sawdust Trail

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Those who responded to the altar call after one of Billy Sunday’s sermons (see video below) were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer.

Before he became a travelling evangelist, and possibly even before he became a Christian, depending on what source you believe, Mr. Sunday played eight seasons of Major League Baseball between 1883 and 1890. During that time, he roamed the outfield for the Chicago White Stockings, Pittsburgh Alleghenys and Philadelphia Phillies. Mr. Sunday left the game with a lifetime .248 batting average, which was pretty good for the pre-modern era. He was also a speedy player who finished in the top ten in stolen bases three times and led the league in outfield putouts in 1888. Read More

A Foot Massage More Painful Than Acupuncture

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A Lowell chiropractor was recently sentenced in federal court in the District of Massachusetts for bribing an IRS agent.

Stephen Jacobs, age 56, was sentenced by U.S. District Court Judge William G. Young to nine months in prison and ordered to pay a fine of $ 10,000.

In October 2014, Mr. Jacobs pleaded guilty to bribery of a public official. According to the indictment, Mr. Jacobs met with an IRS auditor back in August of 2013 to answer questions pertaining to his 2011 federal income tax returns.

During the interview, the examiner asked Mr. Jacobs about two deductions that he had claimed for tax year 2011 – each in the amount of $ 5,000. Mr. Jacobs admitted to paying Read More

Award Winning Tax Expert Predicts Future of Tax Profession

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At our Tax Resolution Marketing and Technology Conference held in Orlando, FL on Jan. 7-9, we told you this was going to happen.

As a pioneer in the tax resolution industry, I see this news as a sign that our industry is starting to “grow-up”. Prior to 1998 there really wasn’t an industry at all. Sure, practitioners we’re helping people with IRS problems but there were no formalized procedures on how to do this work. It was like the wild, wild, west of tax problem resolution. On 7/22/1998, then President Clinton signed into law the IRS Tax Restructuring and Reform Act (TRRA), also known as “The Taxpayers Bill of Rights III, which gave American Taxpayers “rights” they never before could exercise. Taxpayer’s were now afforded the ability to appeal all sorts of collection enforcement actions by the IRS and settle their tax debts for (much) less than Read More

Learn How Tax Professionals Are Connecting With Taxpayers In A Tax Media Network


Join me Thursday, January 22, 2015 for the webinar “Learn How Tax Professionals Are Connecting With Taxpayers In A Tax Media Network”.

If you are hanging out on other professional media sites and not attracting any clients, it is because you are not hanging out at the right place! TaxConnections has developed technology that builds relationships between tax professionals and taxpayers with the focus on converting these relationships to new customers.

Give me thirty minutes of your time and I will teach you how to position your tax reputation in front of millions searching for tax expertise right now. There is a better way to build your client base and it is faster, smarter and inexpensive. It costs less than one dollar a day and Read More

UPDATE TO COMMENTS – Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For The Worldwide Taxation of Nonresident U.S. Citizens?

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This is in response to all the comments received on my post from last week entitled: Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For The Worldwide Taxation of Nonresident U.S. Citizens?

Thank you everyone for the lively discourse. I have to admit that when I sought off writing this blog, I had no idea that it was going to generate as many comments as it did. I just recently learned that it made the WSJ Expat Facebook page (thanks for the “heads up” Walter).

While I recognize that this topic inspires deeply-held beliefs and passionate debate, I have to compliment everyone for keeping the level of discourse both courteous and professional.

I am very impressed (although not surprised) with the vast knowledge that so many of you Read More

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part VI (Final)

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A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

6. Capital Gains Tax – Finance Act 2014 – Vodafone Shareholders – eBrief no. 107/14 (24th December 2014).

On 14th May 2014 the Irish Revenue Authorities issued a detailed Tax Briefing outlining the tax treatment of the Vodafone Return of Value to its Shareholders. I wrote an Explanatory Blog, which was published on this site on 16th May 2014, outlining the comprehensive guidance on the calculation of the base cost for Capital Gains Tax purposes. In my Blog, I discussed the Income Tax Treatment for shareholders who opted for “C Shares”: Read More

How The IRS Turned Carole Hinders’ Life Upside Down

Iowa restaurant owner’s fight against the IRS gains national attention.

A restaurant owner in northwest Iowa has landed in the national news spotlight over her fight with the federal government. Carole Hinders who at the time was 67 years old and a grandmother has operated Mrs. Lady’s Mexican Food in Arnolds Park, Iowa for 38 years.

Nowadays it is most notable for a small business to be in operation for 38 years – especially if it is a restaurant which we all know “come and go”. Even more notable for Ms. Hinders was that she was always in full compliance with her tax obligations. But despite her clean tax record, on May 22, 2013 while settling into a crossword puzzle with her grandchildren she was visited at her home by a pair of IRS agents who stated that they had closed her Read More

The Department of Treasury Issues New Proposed Treasury Regulations Governing Internal Use Software Research Tax Credit Claims

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On Friday, January 16th of 2015, The Treasury Department and Internal Revenue Service (hereinafter the “Service”) released for publication in the Federal Register a notice of proposed rulemaking (REG-153656 -03) concerning the application of the credit for increasing research activities pursuant to I.R.C. § 41 for computer software that is developed by or for the taxpayer, for the taxpayer’s internal use.

These Proposed Treasury Regulations have been long-awaited as the Service previously issued Final Treasury Regulations (T.D. 9104) governing many aspects of the Research Tax Credit (hereinafter “RTC”) back in 2003, but deferred addressing the guidelines dealing with Read More