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New IRS Regs Escalate Tax Consequences of Renouncing Citizenship or Surrendering Green Card

On September 9, 2015, the IRS released long-awaited proposed regulations under Internal Revenue Code (Code) section 2801, which imposes a tax on the recipient of a gift or bequest from certain individuals who relinquished...more

Congress Changes FBAR Filing Deadline

On July 31, 2015, President Obama signed into law P.L. 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act). Despite its name, the Act included a number of tax provisions, one...more

IRS Guidance on FBAR Penalties

On May 13, 2015, the IRS issued interim guidance to its examiners regarding penalties for failure to timely file the Report of Foreign Bank and Financial Accounts (FBAR). By no later than May 13, 2016, this interim guidance...more

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

Intergovernmental Agreement And FATCA

On February 5, Canada and the United States signed an intergovernmental agreement (IGA) to implement the US Foreign Account Tax Compliance Act (FATCA). The IGA came as a surprise to Canadians who were hopeful that FATCA would...more

Canada And U.S. Finally Reach Agreement On FATCA

The long awaited Foreign Account Tax Compliance Act United States – Canada Intergovernmental Agreement (IGA) was released on February 5, 2014, and as anticipated will expand the sharing of information between the two...more

2/10/2014  /  Canada , FATCA , IGAs , International Tax Issues

Credit for Foreign Taxes Paid Not Available Against New 3.8% Net Investment Income Tax

Previously, many U.S. citizens living abroad eliminated their U.S. income tax liabilities with a credit for foreign taxes paid; however, individuals who are subject to the new 3.8 percent net investment income tax (NIIT) may...more

U.S. Department of Treasury Mandates E-Filing of FBAR

Any Report of Foreign Bank and Financial Accounts (IRS Form TD F 90-22.1), the so-called “FBAR,” filed on or after July 1, 2013, must be submitted electronically. Any U.S. citizen or U.S. resident with more than $10,000 U.S....more

8/20/2013  /  FBAR , FinCEN , Foreign Banks , OVDP , U.S. Treasury
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