Archive for the ‘International’ category
April 11, 2012
By Sebastien Chain and Tamara Woods Beginning with the 2011 tax year (i.e., for returns filed April 17, 2012 or later), individual taxpayers will be required to file Form 8938 if he or she has an interest in a “specified foreign financial asset” (“SFFA”) (click for additional information on FATCA requirements) that has a value exceeding a certain threshold. [...]
Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
Comments: 1 Comment
April 3, 2012
By Sebastien Chain and Tamara Woods The Hiring Incentives to Restore Employment Act of 2010 (“HIRE Act”) enacted the Foreign Account Tax Compliance Act (“FATCA”). P.L. 111-47. FATCA greatly increases disclosure requirements and penalties on taxpayers with foreign accounts and assets. These reporting requirements will affect individuals beginning with the 2011 tax year, and are expected [...]
Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
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February 28, 2012
By Jonathan Prokup During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the [...]
Categories: Administrative, International
Tags: IRS, section 7602, state taxes, summons, tax treaties
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February 27, 2012
By: Dustin Covello On February 14, the Financial Crimes Enforcement Network (FINCEN) issued Notice 2012-1, which extends the 2011 and 2012 FBAR filing deadline for certain individuals to June 30, 2013. The notice extends relief previously granted by FINCEN to employees and officers with signature authority over bank accounts owned by subsidiaries of certain regulated [...]
Categories: Administrative, International
Tags: FBAR, FinCEN, offshore bank accounts, OVDI
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February 24, 2012
By Hale Sheppard Many Canadians migrate south each year and become U.S. residents or citizens. Along with the cold weather, they may also leave behind local retirement account, such as a Canadian registered retirement savings plan (“RRSP”) or a Canadian registered retirement income fund (“RRIF”). Preserving this Canadian nest egg is generally a good thing. [...]
Categories: International
Tags: Canadian Accounts, FBAR, international tax, Private Letter Ruling Requests, Registered Retirement Plan, retirement income fund, RRIF, RRSP
Comments: 1 Comment
January 25, 2012
By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes. As expected, the return shows substantial income, [...]
Categories: Administrative, Individual, International
Tags: FBAR, foreign investment, Mitt Romney, offshore bank accounts, OVDI, Penalties, PFIC
Comments: 1 Comment
January 10, 2012
By Jonathan Prokup and Dustin Covello The IRS announced yesterday a reopening of its 2011 offshore voluntary disclosure initiative (“OVDI”). This program will have essentially the same terms as the 2011 OVDI, but with a penalty rate of 27.5 percent (rather than 25 percent) of the highest account balance during the period covered by the [...]
Categories: Administrative, Individual, International
Tags: Credit Suisse, FBAR, HSBC, offshoare bank accounts, OVDI, Penalties, Swiss, tax evasion
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January 9, 2012
By Jonathan Prokup On December 9th, the IRS issued final regulations under Code section 881 that treat a disregarded entity as a person to determine whether a “financing arrangement” exists for purposes of applying the conduit financing regulations. The finalized regulations may deny tax benefits otherwise available from U.S. tax treaties when a multi-party financing [...]
Categories: Administrative, Financial Products, International, Withholding
Tags: anti-abuse, conduit financing transaction, disregarded entities, economic substance, section 7701, tax treaties, withholding taxes
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
