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IRS Announces Changes to the Offshore Voluntary Disclosure Program

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 DOJ Enforcement Enforcement Actions FBAR IRS Offshore Banks Offshore Funds OVDP Penalties Pre-Clearance Tax Penalties TIN UBS

Who Is a U.S. Person? Disparities Between U.S. Tax and Immigration Law

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

3/15/2014 - Citizenship Disparate Treatment Estate Tax Exit Tax FATCA FBAR Income Taxes IRS Lawful Permanent Residents U.S. Person

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

1/11/2013 - Alternative Minimum Tax American Taxpayer Relief Act Capital Gains Dividends Estimated Taxes FATCA Fiscal Cliff Foreign Earned Income Foreign Nationals Foreign Tax Income Taxes Itemized Deductions Payroll Taxes Personal Exemptions Tax Exemptions Tax Rates

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