GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Impuesto de Timbre, ¿otra vez?
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
Musings on Multinational Tax: What to Expect From GILTI Conscience
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more
El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more
On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...more
If you have unreported foreign accounts, you are not alone. Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.). The good news: the IRS offers...more
El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more
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
The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more
Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards - While the IRS has not specifically addressed the taxation of staking rewards, they have indicated a willingness to treat these rewards in...more
The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more
In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more
FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basis, as opposed to a per-form basis. However, a taxpayer with “reasonable cause”...more
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more
The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more