The IRS issued temporary and proposed regulations on the requirement that certain foreign financial assets be reported to the IRS for tax years beginning after March 18, 2010.
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International Tax
IRS Reminds Dual Citizens and Americans Living Abroad of FBAR, Other Filing Requirements
In a fact sheet, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements.
Unreported Offshore Accounts: A Hidden Danger for Clients
Criminal penalties for not reporting offshore accounts can be harsh. This item provides action steps for CPAs.
Passive Foreign Investment Companies
This item assesses various planning alternatives that may help U.S. taxpayers avoid the negative aspects of the PFIC regime, including qualifying electing funds, mark-to-market elections, and various planning strategy options.
Are Hedge Funds and Private Equity Funds Foreign Financial Accounts?
This item discusses whether investments in or management of hedge funds and private equity funds should be included within the scope of the FBAR filing requirements.
Final Regs. Issued on Killer B Transactions
The IRS has issued final regulations to close a loophole (known as Killer B transactions) that allowed one or more foreign corporations involved in a triangular reorganization to repatriate earnings tax free to the United States in certain circumstances.
Tax Court Determines Character, Source of Golfer’s Worldwide Endorsement Income
The Tax Court recently decided Goosen, a case with potentially far-reaching implications for foreign athletes who perform within the United States. The decision has become the leading authority for determining both the character and the source of the endorsement income earned by international athletes.
IRS Will Phase in Implementation of FATCA Requirements
The IRS announced plans to phase in the requirements of the Foreign Account Tax Compliance Act (FATCA) because of numerous comments it has received about the difficulty of implementing the requirements.
Final Regs. Issued on Determining Amount of Tax Paid for Foreign Tax Credit Purposes
Final regulations have been issued that provide guidance on determining the amount of taxes paid for purposes of determining the foreign tax credit.
IRS Clarifies September 9 Extension for Offshore Reporting
The IRS clarified that its postponement of deadlines under the 2011 OVDI also applies to taxpayers filing FBARs and other information returns pursuant to FAQs 17 and 18.
Hurricane Postpones IRS’s Offshore Voluntary Disclosure Deadline
The IRS announced it had postponed the deadline for its 2011 Offshore Voluntary Disclosure Initiative (OVDI). The new due date for requests is September 9, 2011.
When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes?
U.S. LLCs have become the preferred business entity in many situations because their members get both legal liability protection while being taxed in the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return.
Delinquent U.S. Foreign Information Returns: Is Filing Under the 2011 OVDI Appropriate?
This item explains the process by which taxpayers may take advantage of an opportunity to avoid a substantial portion of the penalties that would otherwise be due on previously unreported offshore accounts, entities, and income.
IRS and FinCEN Extend FBAR Deadlines for Certain Filers
The IRS has further extended the deadline for certain persons to file an FBAR form for 2009 and earlier years. U.S. persons with a financial interest in, or signature authority over, any financial accounts in a foreign country must file an FBAR if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.
IRS Removes Form 5472 Duplicate Filing Requirement
The IRS has issued temporary and proposed regulations to remove the duplicate filing requirement for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.
FinCEN Creates FBAR E-Filing System
FinCEN announced that it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
Phased Implementation of FATCA Requirements Announced
The IRS announced plans to phase in the requirements of the Foreign Account Tax Compliance Act (FATCA).
Penalty Relief for Delinquent FBARs and Forms 5471 Ends August 31
The IRS has provided penalty relief in guidance related to its latest offshore voluntary disclosure initiative. The focus of this item is on who qualifies for penalty relief and procedures for obtaining this relief.
Application of CFC Lookthrough Rule to Payments Made by a Partnership to Its CFC Partner
This item examines the controlled foreign corporation (CFC) lookthrough rule.
IRS Matching Program for Forms 8023 and 8883 May Result in Invalid Sec. 338 Election
The IRS recently launched a program to match the filing of Form 8023, Elections Under Section 338 for Corporations Making Qualified Stock Purchases, by a foreign purchasing corporation acquiring a foreign target, with Form 8883, Asset Allocation Statement Under Section 338, to report the effect of the Sec. 338 election.
TAX PRACTICE MANAGEMENT
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