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
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
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more
We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more
When working with an estate planning advisor, it’s critical to disclose all your assets. Importantly, any foreign assets you might have must be included. Often, people assume that these assets aren’t relevant to their “U.S.”...more
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
The Biden’s Administration 2024 Revenue Proposal includes US taxpayer reporting requirements for foreign digital asset accounts. The proposal would be effective for returns required to be filed after December 31, 2023. Tax...more
Taxing the Rich- During the last couple of months, as we headed into what most folks – excluding transactional attorneys – call the “Holiday Season,”[i] tax authorities from around the globe have been calling for increased...more
On 1 August, a new Register of Overseas Entities under the Economic Crime (Transparency and Enforcement) Act 2022 came into force, requiring overseas entities that currently own land in the United Kingdom to register verified...more
Con la Resolución 001096 de 13 de julio de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) de Colombia modificó el instructivo de la casilla 41 de la Declaración Anual de Activos en el Exterior (formulario 160),...more
Economic ripples of Russia’s invasion of Ukraine will permeate the financial, energy, retail, and agricultural sectors, among others. (A link to a related King & Spalding webinar is located here.) While the full effects of...more
As Reuters recently reported, Russia is preparing a new law that will allow it to seize the local businesses of Western companies that have left or suspended operations in Russia due to the invasion of Ukraine. Affected...more
With the continuing exit and suspension of operation of foreign entities in Russia, Russian State authorities are exploring retaliatory measures, including a regime for the nationalisation and forced sale of foreign assets. ...more
The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals (the “Greenbook”), which elaborates on revenue proposals in President Joe Biden’s Fiscal Year 2023 Budget Proposal,...more
8 Key Business Takeaways From Russia’s War - Economic ripples of Russia’s invasion of Ukraine will permeate the financial, energy, retail, and agricultural sectors, among others. (A link to a related King & Spalding...more
Nearly two weeks into the Russian invasion of Ukraine, numerous companies are focused on how the war might impact their business, including their insurance coverage. This advisory provides a high-level overview of two types...more
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days. This frequently happens in an understandable...more
Japan is making bold policy and legislative actions to reshape its regulatory landscape for the asset management industry, aiming to invite more foreign asset managers to Japan and further elevate Japan’s status as a global...more
Many Taxpayers with international entanglements seek the assistance of tax return preparers without U.S. international tax reporting experience. Because US International tax reporting is complicated and often overwhelming...more
Please join us on January 29th as we discuss the following topics on estate and gift tax planning for clients with international ties: - Gifting to a non-citizen spouse - The difference between U.S. “residency” for...more
On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to alert companies that might pay ransomware attackers of the potential sanctions risks for facilitating...more
At the end of June, the Commissioner of the IRS Large Business and International Division announced a new campaign to audit high-net-worth individuals and the entities (such as partnerships, corporations, trusts, and private...more