The Wolfe Law Group is proud to announce that Gary Wolfe was quoted in two recent articles in Forbes Magazine:
“Gary Wolfe, a leading international tax attorney, especially likes this L-1 and E-2 visa approach to U.S. film making because such visas enable him to help foreign investors avoid the significant U.S. tax exposure present in other forms of U.S. immigration options.”
“Now consider the tax issues associated with the EB5 program. Gary Wolfe, a leading international tax attorney, summarized them nicely as follows:
The extent to which a new immigrant is exposed to U.S. taxation is:
1) Imposition of federal and state (e.g. CA) “blended income tax”rates up are to 55 percent.
2) For 2017, U.S. estate and gift taxes of 40 percent (after the personal exemption of $5.49 million or, the combined $10.9 million for a husband and wife plus gift exemptions of$14,000 each for that year, thus totaling $11.26m for husband and wife.)
3) Risk of creditor attachments. Over one million lawsuits are filed yearly in California. Plaintiffs attorneys look for “deep pocket defendants” who hold assets titled in their individual names or closely held entities. Investors often fall into this category.
4) U.S. worldwide information reporting requirements for undisclosed foreign bank accounts. (FBAR filings/FinCen Form 114 for foreign bank accounts over $10 thousand. Failure to file is an annual 50 percent penalty. That can be up to 300 percent if non-tax compliant for 6 years. Willful FBAR failure to file violations can also result in a 10-year felony for each year FBAR is not filed.
5) Foreign Account Tax Compliance Act (FATCA) requires reporting by foreign banks on U.S. account holders (adopted March of 2010 and is effective for tax years thereafter). Form 8938 is a separate tax filing due (attached to Form 1040) for foreign financial assets over $50 thousand. Thus taxpayers with foreign bank accounts over $50 thousand have to file both the FBAR and the FATCA filing (Form 8938) or risk multiple civil and criminal tax penalties.
Consider these now new (2018 forward) tax pitfalls Wolfe has identified:
1. Elimination of multiple federal income tax deductions, such as: a) for alimony paid, and b) for payments in excess of $10 thousand annually for all state, and local income taxes paid, as well as for property and sales taxes paid and casualty losses for personal property (as for example in the wildfires that raged through California in 2017).
2. A one in three chance of an IRS tax audit if earnings and/or net worth exceed $10 million under the little disclosed IRS Tax Wealth Squad (formed in 2010) as a special audit division of the IRS (which evaluates both income and net worth levels, triggered when a US taxpayer receives multiple K-1s from various investments.”
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About the author
With over 30 years of experience, Gary specializes in IRS Tax Audits, International Tax Planning/Tax Compliance, and International Asset Protection. Since 2013, Gary Wolfe has written over 20 eBooks regarding the IRS, International Tax Planning, and Asset Protection. Since 2004, he has published or been interviewed in over 150 articles published by 14 different US and International magazines. He is also the recipient of 17 separate International Tax Awards from 7 different global expert societies in London and the UK. To know more about Gary Wolfe please visit https://www.adamglobal.com/our-member-firms/gary-wolfe/