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Taxpayers may be entitled to refunds or abatements of penalties and interest that the IRS assessed during the nearly 3.5-year COVID-19 federal disaster period. However, this relief will not happen automatically. To protect their rights, most taxpayers must file a claim for refund – generally on or before July 10, 2026.

I hate to be disparaging, but what a pile of ****

Inland Revenue have today released their Fact sheet on legislation that has yet to be written regarding new FIF rules.

https://www.taxpolicy.ird.govt.nz/-/media/project/ir/tp/publications/2025/fs-fif-fund-rule-changes.pdf?modified=20250313233614&modified=20250313233614

Once the legislation has been written, we will circle back with our thoughts.

Inland Revenue issued a discussion document today (6 December 2024) which could have a significant impact on the application of the Foreign Investment Fund rules for migrants.

Whilst it is only a discussion document and not new legislation, it signals a clear intention by the government to make some changes to the rules.

The period for feedback is short with feedback sought by 25 January 2025. If you have strong views on the options, you may want to take a few minutes away from the xmas turkey / barbecue and take a look.

On 21 August 2024, the Internal Revenue Service held a public hearing on the exciting topic of “Transactions With Foreign Trusts and Information Reporting on Transactions With Foreign Trusts and Large Foreign Gifts (REG-124850-08)”  

We want to bring to your attention a new informational reporting, BOIR, required by FinCEN, a bureau of the US Department of Treasury. This new requirement became effective as part of the Corporate Transparency Act (CTA) on 1 January 2024 and applies to certain entities and their beneficial owners.

Whilst we are unable to assist with BOIR reporting, we wanted to bring this to your attention so that you may seek the appropriate advice and take necessary action in advance of the relevant deadline(s).

Today, the IRS issued Notice 2022-36 to provide penalty relief to most people and businesses who file certain 2019 or 2020 returns late. Additional assistance will be provided to those who have already paid these penalties as well.

Find out more here: https://www.irs.gov/pub/irs-drop/n-22-36.pdf

The first thing to note about this article is that it contains only one piece of advice which is this “Do not base your financial decisions on an article that you read on the internet. Go talk with a suitably qualified person about your particular facts”.

Every other item in this article should only be read as commentary and we accept no responsibility for actions that you take as a consequence of reading the article. These are simply musings based on nearly 30 years of providing US tax advice to US citizens outside of the US.

On May 21, 2018, the IRS Large Business & International Division (“LB&I”) announced its fourth set of compliance campaigns.

The six new campaigns include one campaign centered on Forms 3520 and 3520-A compliance. A Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, must be filed to report certain transactions regarding foreign trusts under section 6048 of the Internal Revenue Code, including:

Today, the Internal Revenue Service notified taxpayers that it will be ending the Offshore Voluntary Disclosure Programme (OVDP) in September 2018.

The OVDP is a tax amnesty programme for delinquent taxpayers who were unable to attest that their failure to file was not due to willful action.

For now, the Streamlined Amnesty remains in place, with the IRS simply noting that it will be removed at some point, but with no further details given.

You may be aware that from 1 July 2017, there are changes occurring to Australian superannuation.

The attached is a link to a guide that provides a good (and understandable) overview of the changes

https://www.moneysmart.gov.au/tools-and-resources/news/superannuation-changes-1-july-2017 

Inland Revenue is trying to raise awareness of the upcoming changes to information sharing.  A series of public announcements is scheduled for June and July 2017.

http://www.ird.govt.nz/international/exchange/crs/aeoi-crs/

At least once a month I am asked the question “What is the likelihood of the revenue authorities finding out about my XXXX”.  My response is always the same “What is the likelihood of them not finding out about your XXXX”.

The powers that revenue authorities around the world have, to enquire into your affairs are exceptionally broad (ask those who have been in the cross-hairs of the Inland Revenue), but the ratio of Revenue officers to taxpayers does however necessitate a ‘smart’ approach by revenue authorities to determine who they should be focusing their time on.

Do you have a UK mortgage?

If you have a UK mortgage, grab a bottle of gin before you read on, there is some bad news to come. In fact, if you are paying any mortgage outside of New Zealand (NZ), you should read this, because the concepts I’m about to introduce apply to all NZ taxpayers with an overseas mortgage.

Do you have an Australian Superannuation fund? Are you up to speed with the reforms? The Treasury has issued a series of fact sheets, however given the importance of superannuation, you may wish to seek advice that is specific to you. 

https://www.treasury.gov.au/Policy-Topics/SuperannuationAndRetirement/Superannuation-Reforms 

We work alongside Tony Pitara at Pitara Partners 

Under the Protecting Americans from Tax Hikes (PATH) Act of 2015, any ITIN not used on a federal tax return at least once in the last three years will no longer be valid for use on a tax return as of Jan. 1, 2017. If a taxpayer has an ITIN that is scheduled to expire and needs to file a tax return, it’s important not to delay. By submitting the application package in the next few weeks ITIN taxpayers may avoid unnecessary delays and allow for smoother and faster processing. ITINs are used by people who have tax filing or payment obligations under U.S.