IRS税務弁護士ブログ
IRS審査、税務債務、賃金差押え、オフショア口座等に関する弁護士執筆ガイド — Samuel Landis, Esq.
Los Angeles IRS Tax Attorney: What LA Taxpayers Need to Know About Federal Tax Problems
Los Angeles taxpayers operate in one of the most complex tax environments in the United States. Between the IRS, the California Franchise Tax Board (FTB), and the City of Los Angeles Business Tax, individuals and…
Form 3520 Penalties Explained — And How to Fight Back
6 min read Quick Summary Form 3520 penalties start at 5% of the foreign gift amount per month, capped at 25%. On a $400,000 gift, the maximum penalty is $100,000 — even if you owed zero tax. Penalties can be fought…
I Got a Large Gift From My Foreign Parents — Do I Have to Report It?
5 min read Quick Summary If you received more than $100,000 from foreign parents or relatives in a single year, you must file IRS Form 3520. The reporting deadline is the same as your tax return — typically April 15,…
Filing U.S. Taxes With a Foreign Employer — No W-2, No Problem
U.S. citizens working for foreign companies do not receive a W-2 but still owe U.S. taxes. This guide covers foreign wage reporting, self-employment tax, the Foreign Earned Income Exclusion, the Foreign Tax Credit, and…
TFSA Tax Rules for US Citizens in Canada — What Every Dual Citizen Needs to Know
U.S. citizens holding Canadian TFSAs face annual U.S. income tax with no foreign tax credit relief. Rev. Proc. 2020-17 does not exempt TFSAs. This guide covers PFIC risks, reporting requirements, and planning options.
Foreign Inheritance and U.S. Tax — What You Need to Know Before Accepting an Inheritance
When a Foreign Inheritance Creates U.S. Tax Obligations Receiving an inheritance from a family member abroad is both deeply personal and surprisingly complex from a U.S. tax perspective. If you are a U.S. citizen,…
Form 3520 vs Form 3520-A — What's the Difference and Do You Need Both?
Form 3520 is filed by U.S. persons to report foreign gifts and trust transactions. Form 3520-A is filed by the foreign trust itself. Learn the key differences in who files, deadlines, penalties, and what happens when a…
Form 3520 for Asian-American Families: Reporting Gifts From Parents in China, Japan, Korea, and India
If your parents abroad sent you money, is it taxable? Probably not — but you may still need to file IRS Form 3520. Learn the $100,000 reporting threshold, what counts as a foreign gift, and how to stay compliant…
How to set up a California tax installment agreement
Learn how to set up a California tax installment agreement with FTB or CDTFA. Understand eligibility, apply online, and avoid penalties.
Green Card Holders and the Foreign Gift Tax Trap: What LPRs Must Know
The Moment Your Green Card Changes Everything The day you received your green card, the IRS began treating you exactly like a U.S. citizen for tax purposes — with all the same reporting obligations, penalties, and…
FBAR Filing Requirements for Expats: The Complete Guide to Foreign Bank Account Reporting
Need help with a late FBAR, penalties, or complex foreign account situations? Our FBAR attorneys provide confidential consultations for U.S. taxpayers facing compliance issues or FinCEN enforcement. FBAR Filing…
IRS Passport Restrictions and Foreign Tax Debt: How to Get Your Passport Back
The IRS can restrict or revoke a U.S. passport for serious tax debt. Learn how foreign tax debt, FBAR penalties, back taxes, and expedited decertification work.
PFIC Tax Reporting: The Silent Tax Bomb in Your Foreign Investment Account
Reading time: ~9 min If you are a U.S. taxpayer with investments in foreign mutual funds, foreign ETFs, or pooled investment vehicles held outside the United States, there is a high probability that you own one or more…
How the IRS Voluntary Disclosure Program Works for Foreign Account Holders
If you have undisclosed foreign bank accounts, unreported offshore income, or unfiled international information returns—FBAR, Form 3520, Form 8938—you are already in the IRS’s crosshairs. The question is not whether…
Form 3520 Threshold 2025: Current Year Limits and Historical Table
The 2025 Form 3520 threshold is $100,000 for foreign individuals and $20,116 for foreign corporations. See the complete inflation-adjusted table from 2020–2026, aggregation rules, and penalty details.
How to Get Professional Help with Garnished Wages
Get help with garnished wages now. Learn limits, exemptions, stop strategies, bankruptcy options & professional tax debt relief.
Stop the Stress with an IRS Installment Agreement
Learn how to get an IRS installment agreement fast. Relieve tax debt stress with step-by-step plans, eligibility, fees & alternatives.
The Art of the IRS Deal and Your Back Tax Settlement
Master your back tax IRS settlement. Discover OIC eligibility, application, and how to resolve tax debt and financial hardship.
The Ultimate Guide to Personal Tax Controversy Resolution
Discover how a tax law advocate resolves IRS disputes, stops levies, and secures relief. Your guide to TAS, OIC, and expert strategies.
The IRS Fresh Start Program: Fact vs. Fiction
Discover the Fresh start tax program: real IRS relief options, eligibility, updates for 2025, and how to apply vs. OIC scams. Get tax debt help now!
How to Keep Your Offshore Accounts from Becoming a Shore Subject with the IRS
Resolve San Diego Offshore Tax Issues with FBAR, FATCA compliance, voluntary disclosure & penalty relief from expert San Diego tax attorneys.
Don't Ghost the IRS and Other Audit Letter Tips
Get federal audit letter assistance: Respond to IRS notices, gather docs, avoid mistakes, appeal decisions & protect your rights. Expert tips inside!
Don't Mess with the IRS: A Guide to Houston's Premier Tax Law Firms
Discover top Houston tax law firms for IRS audits, back taxes & resolutions. Expert attorneys deliver freedom—find your guide now!
Free Expat Tax Filing Options That Actually Work
Discover free expat tax filing online options that work: FEIE, FTC, FBAR, FATCA, extensions & streamlined procedures for US expats.