News & Analysis as of September 18, 2024

Foreign Account Tax Compliance Act

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on 9/6/2024

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Weekly IRS Roundup July 15 – July 19, 2024

McDermott Will & Emery on 7/29/2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15, 2024 – July 19, 2024. ...more

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on 2/5/2024

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

International Tax Withholding | Chapter 3 of the Internal Revenue Code

Freeman Law on 10/19/2022

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Can The IRS Collect Assets Abroad?

Foodman CPAs & Advisors on 8/24/2022

The answer to the question “Can the IRS Collect Assets Abroad”” is yes, based on the Office of Chief Counsel Internal Revenue Service memorandum dated February 24, 2022. The memorandum discusses the IRS Collection Procedures...more

Cómo las Administraciones Tributarias Manejan el Incumplimiento de FATCA, CRS

Foodman CPAs & Advisors on 3/4/2022

Las administraciones tributarias pueden utilizar una combinación de medidas de detección, preventivas y correctivas para evaluar y tratar Ley de Cumplimiento Tributario de Cuentas Extranjeras (FATCA) y el incumplimiento del...more

High-Income Individuals And Corporate Tax Returns Are Targets Of IRS Additional Funding Program

Foodman CPAs & Advisors on 5/13/2021

The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net Worth Individuals...more

After Ten Years, FATCA is NOT GOING AWAY!

Foodman CPAs & Advisors on 12/16/2020

FATCA was signed into law in March 2010 with the objective of combating international income tax reporting non-compliance by US citizens and U.S. taxpaying residents (US Taxpayers). It requires Foreign Financial Institutions...more

¿Mantiene su Institución Financiera un Cumplimiento Continuo con FATCA?

Foodman CPAs & Advisors on 12/9/2020

La participación en FATCA no es una opción, llegó para quedarse y es parte de una iniciativa global. FATCA es complicado, y para los banqueros, ha implicado aprender nueva terminología y comprender en exceso de un mil de...more

Breaking Up Is Hard To Do: A Quick Refresher on the U.S. Tax Implications of Expatriating

Bilzin Sumberg on 10/30/2020

Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more

IRS has a Commitment to Service US Taxpayers and Enforce Collections Compliance

Foodman CPAs & Advisors on 6/17/2020

According to the Internal Revenue Code, Taxpayers have three obligations: (1) to file timely returns; (2) to file accurate returns; and (3) to pay the required tax voluntarily and timely. ...more

IRS issues FATCA Relief but not for All

Foodman CPAs & Advisors on 1/17/2020

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens. These are procedures for certain persons who have relinquished, or intend to relinquish, their United States citizenship, who wish to come...more

Weekly IRS Roundup January 6 – January 10, 2020

McDermott Will & Emery on 1/14/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6 – January 10, 2020. January 6, 2020: The IRS issued a News Release confirming that the...more

Collection: Expatriation with No Tax, Interest or Penalties: New Relief Procedures for Certain Former Citizens

Rosenberg Martin Greenberg LLP on 1/6/2020

On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010....more

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

Foodman CPAs & Advisors on 10/11/2019

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more

Treasury and the IRS Release Tax Guidance on the Transition from Interbank Offered Rates

A&O Shearman on 10/9/2019

On October 8, 2019, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a pre-published version of proposed regulations addressing the principal tax consequences related to the...more

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on 6/13/2019

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more

IRS: Las Cuentas Financieras “Offshore” NO pasarán Inadvertidas

Foodman CPAs & Advisors on 5/13/2019

El 15 de marzo del 2019, el IRS informó que la ocultación de dinero o activos en cuentas extraterritoriales (“offshore”) no declaradas permanece en la lista de las estafas tributarias conocidas come la Docena Sucia o "Dirty...more

IRS: Offshore Financial Accounts will NOT go Unnoticed

Foodman CPAs & Advisors on 5/13/2019

On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019....more

Tenga Cuidado con la Campaña de Precisión de Presentación de FATCA del IRS

Foodman CPAs & Advisors on 1/21/2019

El 30 de octubre del 2018, la división Internacional y de Grandes Empresas del IRS (“LBI”) anunció la aprobación de una campaña de cumplimiento que incluye cómo las Instituciones Financieras Extranjeras (“FFIs)) y ciertas...more

Beware of the IRS FATCA Filing Accuracy Campaign

Foodman CPAs & Advisors on 1/21/2019

On October 30, 2018, the IRS Large Business and International division (LBI) announced the approval of a compliance campaign regarding Foreign Financial Institution (FFI) and certain Non-Financial Foreign Entity reporting of...more

2019 Estate and Tax Planning Newsletter

Blank Rome LLP on 1/9/2019

Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2019 by our clients and friends. 1. Transfer Taxes. The major changes made in 2010 in...more

LB&I Announces Five More Compliance Campaigns, Bringing Total To 50 Campaigns

Fox Rothschild LLP on 10/31/2018

The Internal Revenue Service’s Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first 13 campaigns,...more

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

Akin Gump Strauss Hauer & Feld LLP on 10/8/2018

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

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