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Update: Tax Amnesty for Non-Reporting of Foreign Bank Accounts

 

As you may recall from my last in a series of articles on tax amnesty, U.S. taxpayers who failed to file disclosure forms were alerted by the U.S. Treasury on September 21, 2009 of a one-time extension of time to October 15, 2009 to comply with the special voluntary disclosure requirements of the Internal Revenue Service for Americans with unreported income from bank accounts situated outside the United States. As a result, after the deadline passed, many amnesty filings were made with the U.S. Treasury.

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In the recent case of Olmstead v. Federal Trade Commission , the Supreme Court of Florida sent a second wave of hysteria through the limited liability company (?LLC?) planning community by disregarding the charging order protection in the case of a single-member LLC (?SMLLC?). This has resulted in the ringing of the death knell by multiple practitioners of SMLLC planning altogether. Such a conclusion is premature and overreactive at this point in the evolution of the SMLLC.LLCs and Charging Orders.

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Florida Senate - 2011 SB 1152
By Senator Simmons
22-00610B-11 20111152__
Page 1 of 5
CODING: Words stricken are deletions; words underlined are additions.
1 A bill to be entitled
2 An act relating to limited liability companies;
3 amending s. 608.433, F.S.; providing that a charging
4 order against a member’s limited liability company
5 interest is the sole and exclusive remedy available to
6 enforce a judgment creditor’s unsatisfied judgment
7 against a member or member’s assignee; providing an
8 exception for enforcing a judgment creditor’s
9 unsatisfied judgment against a judgment debtor or
10 assignee of the judgment debtor of a single-member
11 limited liability company under certain circumstances;
12 providing legislative intent; providing for
13 retroactive application; providing an effective date.

More. ...

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Most of us have heard the term carbon footprint and have considered its meaning, the long-term effects and possible solutions to the problem. From separating trash to buying hybrid cars, a majority of people have seriously attempted to reduce their carbon footprint. The very definition is a measure of the impact our activities have on the environment as it relates to the amount of greenhouse gases produced in our day-to-day lives, through burning fossil fuels for electricity, heating, fuel consumption, water usage, diet and a host of other factors. A carbon footprint is the measure of all greenhouse gases we produce individually.

Taking a page out of the carbon footprint measurement, we can extrapolate a new way of looking at your wealth by determining your asset protection footprint. Having a large amount of wealth in most instances increases your asset protection footprint. For this discussion, your asset protection footprint will measure the liability exposure of your family name in the world, the amount of property you own, the amount of counties, states and countries you cross, not to mention, how exposed your assets (liquid assets - gold - currency - stocks - bonds) are to creditors. 
 

 

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Section I

If you are working and living overseas or you are a member of the U.S. military on duty outside the United States, you may already know that the deadline for filing your 2010 tax return is usually an automatic extension of two months to June 15, 2011, rather than April 15, 2011.

If you did not meet the June 15, 2011 deadline for filing your 2010 tax return, then you should have availed yourself to one of two extensions that were available to you. The first extension you may have filed on or before June 15, 2011 will extend the filing date to October 17, 2011.  It is important to note that this is an extension of time to file your tax return, not an extension of time to pay the tax you may owe on the return. Also, interest, currently at the rate of 4 percent per year-compounded daily, applies to any payment made after April 18, 2011. There is also the late payment penalty, .5 percent per month, which applies to payments made after June 15, 2011.

If you still cannot get your tax return filed by the October 17, 2011 due date,

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GUN BO, LLC, an Arizona limited liability company, Plaintiff/Judgment Creditor/Appellee,
v.
JOHN CORK, Defendant/Judgment Debtor/Appellant, and
JCSC, LLP, Garnishee/Appellant.

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Just a few more days in Hong Kong and then back to Guangzhou. This is my 21st year of commuting between those two home bases. The two-hour trip between the cities is an enjoyable way to re-acclimate myself to each one’s different pace, environment, and culture.

The trip, by train, is a visit through what used to be China’s cheap manufacturing export district to the West. It’s not anymore. Over the past half-decade, export manufacture has declined. Now Guangzhou has far more days of clear, blue skies than I’d thought possible. Wouldn’t it be nice if we could keep the blue skies while benefiting the economy?

Guangdong Vice-Governor Zhao Yufang recently visited Hong Kong with a large provincial delegation,
offering incentives for investment.

Less than five years ago, there were 60,000 Hong Kong-owned factories in the Pearl River Delta, employing 10 million migrant laborers. The factories were smokestack-topped, high-pollution, cheap-labor sweatshops. They manufactured for the big discount chains.

Times have changed. There are currently 35,000 Hong Kong-owned factories with far fewer employees, albeit they are earning higher wages. Guangdong wants to change — but it will allow some of the high pollution plants to remain, if

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The United States’ East Coast suffered the ravages and beating of Hurricane Irene and on August 29th, the Mayor of New York notified the public that New York City's subways would begin reopening that morning.  On the same day, the IRS announced that the Offshore Voluntary Disclosure Initiative, OVDI, would have its deadline of August 31, 2001 extended by nine days to September 9, 2011. The IRS believed that the Hurricane had an impact on non-filers who still wished to come forward before losing out to the deadline which was affected by the Hurricane. 

 

 

 

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