On April 21, 2020, the IRS released a much-awaited package of guidance in the cross-border tax space that provides relief to those impacted by the COVID-19 pandemic. The guidance relates to (1) day-counting for both tax...more
Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to:
- File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more
On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more
As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more
7/17/2014
/ Credit Suisse ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
FBAR ,
IRS ,
Offshore Banks ,
Offshore Funds ,
OVDP ,
Penalties ,
Pre-Clearance ,
Tax Penalties ,
UBS
The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more