US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Ahora que el IRS lleva cuatro años intercambiando datos de FATCA en sus computadoras y se está embarcando en una Campaña de Exactitud de Presentación de FATCA, existe una urgencia especial para los Contribuyentes...more
Now that IRS has four years of FATCA exchanged data in its computers and is embarking on a FATCA Filing Accuracy Campaign, there is a special urgency for noncompliant U.S. Taxpayers that did not previously exist....more
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more
Foreign asset reporting requirements are nothing new. US taxpayers have long been required to report worldwide income, and the FBAR filing requirements have been around since the 1970s. ...more
Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more
In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more