Estimated Time per Respondent: 89 hours, 44 minute. [sic]
That’s the amount of time the IRS thinks is required to prepare Form 8865.
Give yourself an extra 90 hours of work to do if you are a partner in a foreign partnership. Every stroke of tax planning genius is balanced by a metric ton of paperwork.
Phil Hodgen
Philip D. W. Hodgen is the principal attorney of HodgenLaw PC, an international tax law firm based in Pasadena, California. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law. Admitted to the California bar in 1982, Phil spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991.
Phil is a past chair of the International Tax Committee of the State Bar of California's Tax Section and was a member of the Executive Committee of the State Bar of California's Tax Section for 2004-2007. Phil frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, and real estate professionals.
You cannot do a tax-free rollover of your RRSP into an IRA. An Individual Retirement Account in the United States is the equivalent of the Registered Retirement Savings Plan in Canada. One idea people have is that if they are going to live in the United States permanently they would like to roll over their…
There’s a deal in place, says the Wall Street Journal. No details yet, so let’s see if/how much the Swiss have bent on secrecy. At least all of my UBS clients are in the pipeline already. 🙂
For your reading pleasure, here is Notice 2009-62. If you have signature power over a foreign financial account but the money isn’t yours, then you have an extension of time to deal with the “Come to Jesus!” clean-up and file all of your paperwork with the IRS. If this applies to your particular situation, it…
According to Reuters, UBS has settled with the IRS. Names will be named. (How many? Yours? We shall see.) Beans will be spilled. Fingers will be pointed. Bureaucratic chests will be puffed outward. Meanwhile, back on earth. . . . (I have been accused of being obtuse in the past. By my wife. Let me…
Jack Townsend has — as usual — a thoughtful analysis of the implications of the UBS settlement in which UBS will cough up a few thousand names of U.S. taxpayers. (Exact details of the settlement haven’t been publicized yet.) It seems clear to me (and to Mr. Townsend) that the settlement depends on the Swiss…
Here’s a lightly adapted version of the letter we use. If you want to launch your own voluntary disclosure for your offshore account, here’s what to do: Go to the IRS website and find the address and phone number for the IRS Criminal Investigations office for where you live. Call them and get their fax…
Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.
