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Individuals and Businesses Prepare For FATCA Deadline

Author: Jacob Stein • Tags: foreign, tax law • Posted on: Feb 20, 2014

Individuals and Businesses Prepare For FATCA Deadline

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U.S. Congress Goes After Apple, or Is It Ireland?

Author: Jacob Stein • Tags: foreign, offshore, tax law • Posted on: Jun 03, 2013

Senate hearings about Apple's alleged tax avoidance have been in the news the last few weeks. News stories abound, describing how Apple generates billions of dollars in profits overseas, using a chain of entities set up in Ireland, pays no U.S. income taxes on those profits and pays almost no income taxes in Ireland. The alleged scandal is so delicious, few reporters passed it up.

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Citizenship for Sale in the Caribbean

Author: Jacob Stein • Tags: asset protection, foreign, investment, irs, offshore, planning, tax law • Posted on: Feb 12, 2013

Here is an interesting article from AP about citizenship for sale in the Caribbean. Most nations sell citizenship, or at least permanent residence with a path to citizenship (including the U.S. and many EU nations) - Caribbean nations make it very affordable. We have helped our clients obtain citizenship in various countries, mostly in East Caribbean. The need for a second citizenship is usually fueled by tax planning (i.e., the client is planning to surrender primary citizenship) or politics (if you may need to flee Russia or Saudi Arabia someday, you need a second passport). Costs and difficulty of obtaining second citizenship varies by country, but in all cases the most important consideration is the ability to travel using the second passport. For example, an individual holding a U.S. or a Schengen passport may travel most anywhere in the world without a visa. The same is not true for citizens of many Caribbean nations.

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Several More Swiss Banks Under Scrutinty

Author: Jacob Stein • Tags: foreign, irs, swiss banks, tax law • Posted on: Sep 21, 2011

The U.S. government is requesting information on American account holders from several more Swiss banks. These banks include the giant Credit Suisse, as well as HSBC, Julius Baer Group Ltd., Wegelin & Co., Basler Kantonalbank and Zuercher Kantonalbank. These banks are apparently under secret grand jury investigation in the U.S. The banks have not yet commented on the inquiry.

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IRS Announces Second Amnesty for Foreign Bank Accounts

Author: Jacob Stein • Tags: foreign, irs, offshore, tax law • Posted on: Feb 08, 2011

According to a press release issued by the Internal Revenue Service, U.S. taxpayers with foreign bank accounts now have a second chance to come forward a plead mia culpa.  The new program has a deadline of August 31, 2011.  The taxpayers who come forward will be subject to penalties and interest on unpaid taxes for the past 8 years, and an additional penalty of 25% of the highest balance in the offshore account.

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Advantages of Foreign LLCs

Author: Jacob Stein • Tags: asset protection, foreign, llc, offshore • Posted on: Aug 16, 2010

Many foreign jurisdictions have enacted LLC statutes.  A lot of these jurisdictions are so-called tax havens, which generally means that an entity organized in that jurisdiction will not be taxed by that jurisdiction if the entity is not conducting any business in the jurisdiction.  If a U. S. business or U. S. real estate is owned by an entity organized in a tax haven, the entity will not be doing any business in the tax haven and will not be taxed there.

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Swiss Parliament Votes to Block Disclosure, For Now

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Jun 09, 2010

A week after the upper house of the Swiss parliament voted to allow disclosure of UBS clients to the US government, the lower house of Switzerland’s parliament voted to prevent the disclosure of the names and financial secrets of as many as 4,450 Americans who held undeclared accounts at UBS.

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Update on FBARs and UBS: The Fun Begins

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: May 12, 2010

The quagmire involving US taxpayers with unreported foreign bank accounts continues.  The latest word:  IRS has over 200 dedicated agents conducting audits of those taxpayers who voluntarily disclosed them prior to the October 15, 2009 deadline.  These agents are conducting full audits of the taxpayers who came forward (where there is smoke, there is fire, and potentially other unreported tax issues) and looking to impose fairly significant civil tax penalties.  The audits also extend to those taxpayers who voluntarily came forward following the amnesty deadline, hoping to avoid criminal sanctions.

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HIRE Act Incorporation Foreign Account Reporting Requirements

Author: Jacob Stein • Tags: foreign, tax law, trust • Posted on: Apr 13, 2010

The Hiring Incentives to Restore Employment (HIRE) Act (Pub. L. No. 111-14) was signed into law on March 18, 2010. The Act creates tax breaks for businesses hiring new workers and extending higher expensing limits for small businesses that make capital investments. The Act also incorporates provisions of the Foreign Account Tax Compliance Act of 2009, which has far-reaching implications for foreign financial institutions that may have U.S. clients.

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Swiss Court Reaches Out to Protect Our Clients

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Mar 01, 2010

On January 22, 2010 the Swiss Federal Administrative Court published its first judgment with respect to the IRS’s request for information.  The case relates to a UBS client who failed to provide the bank with a Form W-9.

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Amnesty Passes; UBS Sends Letters to Clients

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Oct 16, 2009

As the October 15 deadline has come and gone, more and more of our clients have reported receiving letters from UBS.

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IRS Extends Amnesty Deadline

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Sep 22, 2009

The Internal Revenue Service has extended the deadline to participate in the FBAR amnesty program to October 15, 2009, and has indicated that there will be no more extensions.

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Details of UBS Deal Revealed

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Aug 19, 2009

The IRS has announced today that UBS will reveal names of 4,450 American account holders.  The actual names have not yet been released, and over the next few months these account holders will receive notices from UBS that their names will be disclosed to the IRS.  The account holders will then have the option of appealing the proposed disclosure to the Swiss appellate court on the grounds that the disclosure would violate Swiss banking secrecy laws.  It is not yet clear how successful such appeals may be.

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Swiss Banks Close Their Doors

Author: Jacob Stein • Tags: asset protection, foreign, tax law • Posted on: May 06, 2009

Every day more and more Swiss banks say "no" to US business. This year alone 7 Swiss banks that we regularly did business with told us that they will be kicking out all US clients and not accepting any new business.

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IRS Extends Its Hand to Taxpayers and Once Again Reaches Deep into Our Pockets

Author: Jacob Stein • Tags: foreign, irs, offshore, tax law • Posted on: Mar 31, 2009

Several years ago the Justice Department subpoenaed names of Americans who had Visa and MasterCard accounts with offshore banks. The IRS then offered these taxpayers a choice, come forward voluntarily and we will waive criminal prosecution and some monetary penalties, or wait until we get to you and then take the risk of criminal penalties.

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Update on Swiss Banks

Author: Jacob Stein • Tags: foreign, irs, tax law • Posted on: Mar 21, 2009

Last week I travelled to Zurich to meet with several Swiss private banks. We do a lot of business with Swiss banks, and the past few months have brought about many changes.

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Continued Fallout from UBS

Author: Jacob Stein • Tags: foreign, irs, offshore, tax law • Posted on: Aug 18, 2008

The UBS scandal may have had a more profound impact on asset protection planning than previously suspected.

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The Ten Largest Banks in the World

Author: Jacob Stein • Tags: asset protection, bank, foreign • Posted on: Aug 11, 2008

It always surprises Americans that the U.S. banks that they have all heard about so much are not necessarily the largest banks in the world.

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IRS Goes After UBS AG

Author: Jacob Stein • Tags: foreign, irs, offshore, tax law • Posted on: Jul 08, 2008

Following the indictment of several UBS AG (Switzerland) employees, the Justice Department requested permission from federal court to have the Internal Revenue Service issue John Doe summons to UBS AG (the Swiss parent of UBS). The John Doe summons will instruct the Swiss bank to provide to the IRS information on all U.S. taxpayer who may have bank accounts with the bank in Switzerland.

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Downturn in the Real Estate Market Leads to More Asset Protection Planning

Author: Jacob Stein • Tags: asset protection, foreign, offshore, planning • Posted on: Mar 20, 2008

Following the credit crunch of August 2007, the real estate market has experienced a significant decline. Many of our clients are heavily invested in real estate or are involved in various development projects. For them, the reality of the declining market means a lot more than an interesting headline. It means that their entire estate may be facing a risk of loss. Here is a real life example.

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Latest Video Bob Klueger Estate Tax Law Video Bob Klueger talks about the effects of the new tax law.
Featured Article speaks with asset protection specialist Jacob Stein of Klueger & Stein, LLP in Los Angeles about the importance of protecting valuable assets, such as your private residence, rental real estate, investments and retirement plans.