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# Sommers-Taxapedia

Your Tax Resource

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## Posts

- [Blog](https://sommers-taxapedia.com/blog/)
- [FBARS – THE BASICS](https://sommers-taxapedia.com/fbars-the-basics/) - The FBAR Filing Requirement With certain limited exceptions, U.S. taxpayers with ownership or signature authority over one or more foreign bank and investment accounts containing at least $10,000 (in cash or assets) in the aggregate on one or more days during the calendar year must file an FBAR (Report of foreign bank and financial accounts),
- [Foreign Gift of an NFT, Part 1](https://sommers-taxapedia.com/foreign-gift-of-an-nft-part-1/) - Introduction: What are a U.S. taxpayer’s reporting duties when receiving a foreign gift of a non-fungibletoken (NFT)? Let’s say your rich foreign uncle, who made a bundle buying NFTs, transfers oneof them to you as a gift. The good news is foreign gifts are not immediately taxed; however, therecould be current IRS filing obligations with
- [Taxation of Cybercurrency Exchanges](https://sommers-taxapedia.com/taxation-of-cybercurrency-exchanges/) - Internal Revenue Code Section 1031 defers taxation involving exchanges of like-kind property held for investment or business. If a taxpayer traded one parcel of real estate for another, the transaction is, in general, tax-free. Congress changed Section 1031, commencing January 1, 2018, applying it solely to real estate. But what about exchanges of cryptocurrency prior
- [Form 3520: Foreign Gift of Cryptocurrency and Other Assets](https://sommers-taxapedia.com/form-3520-foreign-gift-of-cryptocurrency-and-other-assets/) - Introduction: Say you receive a gift or inheritance1 from a foreign individual of cryptocurrency, or other assets, including cash: First, the good news – the gift is not taxable to either the foreign donor (giver) or the done (recipient) – you receive the gift tax free. The bad news, check out these potential filing and
- [The Unresolved Tax Consequences Involving Cybercurrency Staking](https://sommers-taxapedia.com/the-unresolved-tax-consequences-involving-cybercurrency-staking/) - Introduction: There is a raging debate on social media about whether the activity of cybercurrencystaking is similar to a baker who creates a cake using raw ingredients and is not taxed until thecake is sold, or whether staking involves personal services and the taxpayer is receiving assets(new coins) as compensation, in which case, receipt of
- [Taxation of Student Athletes](https://sommers-taxapedia.com/taxation-of-student-athletes/) - With the recent Supreme Court decision in NCAA v Alston (decided June 21, 2021), student athletes may now capitalize on their name, image and likeness (NIL), similar to professional athletes. Depending on the annual revenue, athletes may need to engage in complex and sophisticated business and tax planning, as this income, along with associated deductions,
- [Understanding Form 3520, Reporting Foreign Gifts](https://sommers-taxapedia.com/understanding-form-3520-reporting-foreign-gifts/) - Little-known Form 3520 is required for reporting gifts or inheritances received from one or more foreign individuals totaling $100, 000 or more during the calendar year. Attorney Robert L. Sommers is based in San Francisco and is a Certified Tax Specialist, California Board of Legal Specialization, State Bar of California. He has represented hundreds of
- [Let’s Audit Trump’s Tax Returns](https://sommers-taxapedia.com/lets-audit-trumps-tax-returns/) - To understand some of the issues contained in Trump’s tax returns, let’s assume the role of an IRS auditor and examine Trump’s tax returns based on the information available in news reports, principally the New York Time’s (NYT) massive investigation published on September 28, 2020. 1. Disguised Gifts: Fred Trump (Donald’s father) apparently made numerous
- [FBARS: Is Your On-Line Gambling Or Virtual Currency Account Reportable?](https://sommers-taxapedia.com/fbars-is-your-on-line-gambling-or-virtual-currency-account-reportable/) - With certain limited exceptions, U.S. taxpayers with one or more foreign bank and investment accounts containing at least $10,000 (in cash or assets) in the aggregate during the calendar year must file an FBAR (Report of foreign bank and financial accounts), FINCIN Form 1141. This obligation is separate from your obligation to file income tax
- [U.S. Tax Laws Involving Foreign Income, Assets and Financial Accounts](https://sommers-taxapedia.com/u-s-tax-laws-involving-foreign-income-assets-and-financial-accounts/) - 1. U.S. Taxpayers (generally individuals physically present in the U.S. 121 days or more during a calendar year, long-term residents and citizens) must report their world-wide income, credits and deductions on U.S. tax returns (Form 1040) and, in general, are entitled to foreign tax credits for income taxed by a foreign country. Non-residents are subject
- [IRS Disclosure Programs for Unreported Foreign Income, Assets and Financial Accounts](https://sommers-taxapedia.com/irs-disclosure-programs-for-unreported-foreign-income-assets-and-financial-accounts/)
- [Announcing a New Tax Brief: Tax Planning for Cryptocurrencies](https://sommers-taxapedia.com/announcing-a-new-tax-brief-tax-planning-for-cryptocurrencies/) - Introduction I’ve written a Tax Brief discussing long-term U.S. tax planning for cryptocurrency investors. Every such investor must be fully aware of the potential tax traps and planning opportunities involving cryptocurrencies. My Tax Brief runs the gambit from absolute disaster and financial ruin to extremely favorable taxation, including in some cases, cryptocurrency gains without federal
- [IRS is Gunning for Unreported Cryptocurrency Transactions](https://sommers-taxapedia.com/irs-is-gunning-for-unreported-cryptocurrency-transactions/) - Note: For more information on cryptocurrency taxation and tax planning strategies, purchase my Tax Brief for just $9.95: Cryptocurrency Income Tax Planning: A Tax Brief Warning Letters: It’s been all over the news that IRS mailed 10,000 letters to potential cryptocurrency participants, warning them that IRS suspects they have engaged in cryptocurrency transactions (IRS uses the

## Pages

- [Home](https://sommers-taxapedia.com/) - Robert L. Sommers of San Francisco, California, is a sole practitioner, with more than 48 years experience as a practicing tax attorney. An international and domestic tax strategist, he has represented and advised numerous U.S. and foreign individuals and small companies on a variety of tax, business and estate planning matters since 1976. As an
- [Books](https://sommers-taxapedia.com/books/) - Library of Books for Purchase The Fractional Worker Tax Trap: A Tax Brief The book analyzes the rapidly expanding use of so-called “fractional” workers through the lens of long-settled tax principles that elevate substance over labels.Read MoreBuy Now $9.95 Changing California Tax Residency: A Tax Brief This Tax Brief provides important information for residents who
- [Videos](https://sommers-taxapedia.com/videos/) - Media: Book Trailer Videos & Tax News Boomer Bob's Tax Cafe and Coffee Bar: The Fractional Worker Tax Trap The New 2025 Tax Bill Intergenerational Transfer of Wealth Changing California Tax Residency: Welcome To the Hotel California Unresolved Tax Consequences Involving Cybercurrency Form 3520: Foreign Gift of a Non-Fungible Token (NFT) Form 3520: Foreign Gift
- [The Fractional Worker Tax Trap](https://sommers-taxapedia.com/books/the-fractional-worker-tax-trap/) - A Tax Brief The Fractional Worker Tax Trap strips away marketing slogans and examines how federal and state tax law actually operates. The book analyzes the rapidly expanding use of so-called “fractional” workers through the lens of long-settled tax principles that elevate substance over labels. Through careful legal analysis, practical checklists, and direct, detailed discussion
- [Boomer Bob's Tax Cafe](https://sommers-taxapedia.com/videos/boomer-bobs-tax-cafe/) - The Fractional Worker Tax Trap The New Tax Bill 2025 Intergenerational Transfer of Wealth Welcome To the Hotel California What I Actually Do For My Clients The Unresolved Tax Consequences Involving Cybercurrency Staking Form 3520: Foreign Gift of a Non-Fungible Token (NFT) Form 3520: Foreign Gift of Cryptocurrency or Cash Taxation of Cybercurrency Exchanges Taxation
- [The New Tax Bill 2025 Video](https://sommers-taxapedia.com/the-new-tax-bill-2025-video/) - Robert L. Sommers, tax attorney (aka "The Tax Prophet") makes a presentation at the Executives Association of San Francisco luncheon, talking about the new tax bill and how it will effect your personal taxes, investments, and business decisions, and your estate plan. (August 2025)
- [Tax Guide Books](https://sommers-taxapedia.com/videos/tax-guide-books/) - Cryptocurrency Income Tax Planning: A Tax Brief A Guide to Practical Asset Protection Independent Contractor vs. Employee Quagmire
- [Attorney Bio](https://sommers-taxapedia.com/attorney-bio/) - Robert L. Sommers of San Francisco, California, is a sole practitioner, with more than 48 years experience as a practicing attorney. An international and domestic tax specialist, he has represented and advised numerous U.S. and foreign individuals and small companies on a variety of tax, business and estate planning matters since 1976. For 35 years,
- [Contact](https://sommers-taxapedia.com/contact/) - By sending an email or contact form, you understand and agree that: (1) That Mr. Sommers is under no obligation to respond to your email; (2) Any and all responses made by Mr. Sommers are for educational purposes only and do not constitute legal or tax advice; and (3) No attorney-client relationship is created between
- [Unresolved Tax Consequences Involving Cybercurrency Staking: Video](https://sommers-taxapedia.com/unresolved-tax-consequences-involving-cybercurrency-staking-video/)
- [Cryptocurrency Income Tax Planning](https://sommers-taxapedia.com/books/cryptocurrency-income-tax-planning/) - Cryptocurrency Income Tax Planning: A Tax Brief This Tax Brief focuses on U.S. federal income tax consequences of investing in cryptocurrencies on a regular or long-term basis. It is not intended for cryptocurrency miners or those holding cryptocurrencies for sale to customers. There are on-line sources describing how to calculate your gains and losses from
- [Changing California Tax Residency](https://sommers-taxapedia.com/books/california-residency-tax-issues/) - Changing California Tax Residency: A Tax Brief California is a notorious high-tax state that aggressively pursues its residents who move to another state and contend they no longer owe California taxes. The main bone of contention usually involves stock or security sales, where the taxpayer argue they were living in another state (usually a no-tax
- [Double Irish-Dutch Tax Sandwich](https://sommers-taxapedia.com/double-irish-dutch-tax-sandwich/) - Demonstration of a Double Irish-Dutch Tax Sandwich
- [Form 3520: Foreign Gift of a Non-Fungible Token (NFT)](https://sommers-taxapedia.com/form-3520-foreign-gift-of-a-non-fungible-token-nft/) - Robert L. Sommers explains the tax implications if you receive a foreign gift of a non-fungible token (NFT)
- [Form 3520: Video](https://sommers-taxapedia.com/form-3520-video/) - Understanding Form 3520: Reporting Foreign Gifts
- [Form 3520: Foreign Gift of Cryptocurrency or Cash - Video](https://sommers-taxapedia.com/form-3520-foreign-gift-of-cryptocurrency-or-cash-video/) - Say you receive a gift or inheritance1 from a foreign individual of cryptocurrency, or other assets, including cash: First, the good news – the gift is not taxable to either the foreign donor (giver) or the done (recipient) – you receive the gift tax free. The bad news, check out these potential filing and disclosure requirements
- [FBARS: Virtual Currency Account Reportable: Video](https://sommers-taxapedia.com/fbars-is-your-on-line-gambling-or-virtual-currency-account-reportable-video/) - Is Your On-Line Gambling Or Virtual Currency Account Reportable?
- [Taxation of Cybercurrency Exchanges: Video](https://sommers-taxapedia.com/taxation-of-cybercurrency-exchanges-video/)
- [Taxation of Student Athletes: Video](https://sommers-taxapedia.com/taxation-of-student-athletes-video/)
- [Pre-Immigration Tax Planning: Video](https://sommers-taxapedia.com/pre-immigration-tax-planning-video/)
- [IRS Is Coming After Cryptocurrency Transactions: Video](https://sommers-taxapedia.com/irs-is-coming-after-cryptocurrency-transactions-video/)
- [NFT Taxes, Reporting Non-Fungible Tokens: Video](https://sommers-taxapedia.com/nft-taxes-reporting-non-fungible-tokens-video/)
- [Celebrating Your Victorious Tax Conquest](https://sommers-taxapedia.com/celebrating-your-victorious-tax-conquest/)
- [Tax Articles](https://sommers-taxapedia.com/tax-articles/) - Newsletters | Categories MOST RECENT ARTICLESEmployee Stock OptionsEmployment LawForeign TaxpayersGeneral Tax InformationGifts and EstatesSon-Of-Boss Tax Shelter SchemeTax-planning-for-CryptocurrenciesTax & Trust ScamsTax SheltersTaxpayers with Foreign Income or AccountsWealth Preservation
- [Newsletter Archives](https://sommers-taxapedia.com/newsletter-archives/) - IRS Settlement Program – Independent Contractors vs. Employees(December 2011)Independent Contractor vs. Employee: The Basics (Part 3 of 3)(November 2011)Independent Contractor vs. Employee: The Basics (Part 2 of 3)(October 2011)Independent Contractor vs. Employee: The Basics (Part 1 of 3)(September 2011)Buffet on Taxes (August 2011)Foreign Gifts and Inheritances (July 1, 2011)Foreign Bank Accounts and Undisclosed Income: IRS’s 2011 Offshore
- [Independent Contractor vs. Employee Quagmire](https://sommers-taxapedia.com/books/independent-contractor-vs-employee-quagmire/) - Independent Contractor vs. Employee Quagmire is a practical guide for companies and workers engaging in independent contractor relationships, as well as their tax professionals. A must-read for any company or worker who is contemplating a contractual relationship, taxpayers who are facing a federal or state or employment audit, and tax professionals. If a company treats
- [A Guide to Pragmatic Asset Protection](https://sommers-taxapedia.com/books/a-guide-to-pragmatic-asset-protection/) - Pragmatic Asset Protection is a practical guide for individuals seeking to protect their assets from creditors. The methods discussed fall squarely within the U.S. legal system and do not involve hiding assets offshore or other transparently phony schemes. This publication is the product of the author's extensive experience, including his work for the U.S. government
- [Failure to Disclose Foreign Financial Assets](https://sommers-taxapedia.com/books/failure-to-disclose-foreign-financial-assets/) - Robert L. Sommers, an experienced tax attorney specializing in foreign tax issues, has produced a Tax Brief aimed at U.S. taxpayers who may have: foreign bank or brokerage accounts; foreign income or assets, or; received (or will receive) a foreign gift or inheritance. Sommers lays out the filing and reporting requirements under the Internal Revenue
- [Son-Of-Boss Tax Shelter Scheme](https://sommers-taxapedia.com/son-of-boss-tax-shelter-scheme/) - Introduction This website uses the infamous son of Boss tax shelter as a tool to explain how our tax code has been manipulated by some of the sharpest and most devious minds in the country. At its core, the son of Boss tax shelter involves the same concept employed by other tax shelters to reduce
- [Son-Of-Boss Court Decisions](https://sommers-taxapedia.com/son-of-boss-tax-shelter-scheme/son-of-boss-court-decisions/) - Kornman & Assoc., Inc. v. United States 527 F3d 443 (5th Cir. 5/12/08). In Kornman, the Fifth Circuit held that a variant of the son-of-Boss tax shelter lacked economic substance, noting that the obligation to close a short sale position was a "liablity" under the partnership tax law (IRC Sec. 752). Carlos E. Sala et ux.
- [Son of Boss IRS Documents](https://sommers-taxapedia.com/son-of-boss-tax-shelter-scheme/son-of-boss-irs-documents/) - 1. TREASURY SHUTS DOWN "SON OF BOSS" ABUSIVE TAX SHELTER August 11, 2000 LS-831 The Treasury Department and the Internal Revenue Service on Friday issued a notice to shut down another abusive tax shelter that is being marketed and sold. This new scheme is similar in design to the so-called Bond and Option Sales Strategy,
- [Son-Of-Boss Transaction](https://sommers-taxapedia.com/son-of-boss-tax-shelter-scheme/son-of-boss-transaction/)
- [Inflated Basis Transaction](https://sommers-taxapedia.com/son-of-boss-tax-shelter-scheme/inflated-basis-transaction/)
- [Specialty Areas](https://sommers-taxapedia.com/specialty-areas/) - In addition to advising CPA and Attorneys regarding tax matters and testifying as an Expert Witness in tax and trust cases, Robert L. Sommers has been involved in the following specialty areas: Derivium Capital - IRS and State audits involving 90% stock loan transactionsOwnership Continuity and Control Plan - a comprehensive structuring for U.S. or
- [Practice Areas](https://sommers-taxapedia.com/practice-areas/) - Types of Clients Robert L. Sommers represents U.S. and foreign individuals, entrepreneurs, start-ups and small companies, including: Closely-held CorporationsS CorporationsLimited Liability CompaniesTrusts and Estates Description of Services Robert L. Sommers has a general tax and business law practice, with emphasis on the following areas of law: Federal and California income, estate and gift tax controversies,
- [LEGAL SERVICES](https://sommers-taxapedia.com/legal-services/) - Types of Clients Robert L. Sommers represents U.S. and foreign individuals, entrepreneurs, start-ups and small companies, including: Closely-held CorporationsS CorporationsLimited Liability CompaniesTrusts and Estates Description of Services Robert L. Sommers has a general tax and business law practice, with emphasis on the following areas of law: Federal and California income, estate and gift tax controversies,
- [Expert Witness](https://sommers-taxapedia.com/expert-witness/) - Three reasons to choose Robert L. Sommers as your expert witness: Communication Skills – Bob speaks and writes in clear English and uses easy to comprehend analogies and diagrams to illustrate his expert testimony. Litigation Savvy – Bob has been practicing law for more than 40 years, 32 of which as a tax specialist. Bob understands the
- [Disclaimer / Privacy Policy](https://sommers-taxapedia.com/disclaimer-privacy-policy/) - Disclaimer Regarding Use This website provides information of a general nature for educational purposes only and is not intended to be legal or tax advice. This information has not been updated to reflect subsequent changes in the law, if any. Your particular facts and circumstances, and changes in the law, must be considered when applying

## Categories

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- [Tax Planning](https://sommers-taxapedia.com/category/tax-planning/)
- [Cryptocurrencies](https://sommers-taxapedia.com/category/cryptocurrencies/)
- [Tax Shelters](https://sommers-taxapedia.com/category/tax-shelters/)
- [Taxpayers with Foreign Income](https://sommers-taxapedia.com/category/taxpayers-with-foreign-income/)
- [Trump](https://sommers-taxapedia.com/category/trump/)
- [International Tax Law](https://sommers-taxapedia.com/category/international-tax-law/)
- [Cryptocurrency Tax](https://sommers-taxapedia.com/category/cryptocurrency-tax/)
- [Form 3520](https://sommers-taxapedia.com/category/form-3520/)
- [Foreign Gifts](https://sommers-taxapedia.com/category/foreign-gifts/)
- [Tax Filing Requirements](https://sommers-taxapedia.com/category/tax-filing-requirements/)
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