US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
THE WAY WE WERE
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more
The number of virtual currency types has added to this problem. According to TIGTA, the number of virtual currencies has grown significantly since April 2020, from 5,000 to over 26,000 (420 percent) as of July 2023. The two...more
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
The Financial Conduct Authority has published information regarding landing slots under the incoming overseas funds regime for firms currently operating under the temporary marketing permissions regime. The landing slots...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
Los contribuyentes que intencionalmente han no han cumplido con obligaciones tributarias o relacionadas con impuestos pueden resolver su incumplimiento y limitar su exposición a un proceso penal presentando una solicitud a la...more
Taxpayers that have willfully failed to comply with tax or tax-related obligations may be able to resolve their non-compliance and limit their exposure to criminal prosecution by filing an application to the IRS Voluntary...more
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and...more
The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
El 11/04/24, el IRS concluyó su Lista de la Docena Sucia de 2024 con una “advertencia a los contribuyentes sobre los promotores que venden estrategias fiscales falsas y esquemas extraterritoriales fraudulentos diseñados para...more
On 4/11/24, the IRS wrapped up its 2024 Dirty Dozen List with a “warning to taxpayers regarding promoters selling bogus tax strategies and fraudulent offshore schemes designed to reduce or avoid taxes altogether”. Tax...more
What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
A key initial decision for a manager launching a new hedge fund is to decide between: A “master-feeder” fund structure: In a typical “master-feeder” structure, an onshore “feeder” fund and an offshore “feeder” fund both...more
Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more
The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more
ファンドの 投資家 がファンドに対して償還 請求権を有するオープンエンド型ファンドは、 流動性 のある 資産に投資するヘッジファンド等ファンド に適している一方、プライベートエクイティ、ベンチャーキャピタル、不動産等の非流動資産に投資するファンドは、投資が実現するまでにより多くの時間を必要とし、クローズドエンド型ストラクチャーが適しています。...more
As issues of high taxation, complex financial laws and economic and political instability continue to affect the onshore world, the attractiveness of the Cayman Islands as a location for establishing private equity, venture...more
Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more
On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more