Most non-US persons who are properly advised regarding US real estate ownership will structure their holdings to include some combination of US LLCs, non-US companies, non-US partnerships, non-US trusts and/or non-US...more
3/14/2019
/ Corporate Taxes ,
Filing Deadlines ,
Filing Requirements ,
Foreign Ownership ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Property Owners ,
Real Estate Transactions ,
Related Parties ,
Reporting Requirements ,
Tax Liability ,
Tax Penalties
Words Matter -
So, you’re cruising along in the pre-FATCA/CRS world, providing fiduciary services for your clients, setting up accounts in either the name of the trust, foundation, underlying company or other wealth...more
11/21/2018
/ Banking Sector ,
Beneficial Owner ,
FATCA ,
Financial Adviser ,
Financial Reporting ,
Foreign Financial Institutions (FFI) ,
Investment Companies ,
Investment Management ,
NFFE ,
Partnerships ,
Trustees ,
Trusts ,
Wealth Management
The Common Reporting Standard (“CRS”), following along the precedent set by the Foreign Account Tax Compliance Act (“FATCA”), creates the concept of “accountholders” in structures such as trusts, foundations, companies and...more
Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more
7/6/2018
/ Citizenship ,
Expatriates ,
FBAR ,
Filing Requirements ,
Financial Planning ,
Foreign Earned Income ,
Income Taxes ,
IRS ,
Offshore Funds ,
Pensions ,
Tax Advice ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Treaty ,
Voluntary Disclosure
The Organization for Economic Co-operation and Development (the “OECD”) has published version 2.0 of its Common Reporting Standard (the “CRS”) Implementation Handbook (the “Handbook”)....more
The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more