FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE THIRD IN A SERIES ABOUT OTHER US TAX SURPRISES – REPORTING REQUIREMENTS – IRS FORM 5471 – Category 3 Filers

US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided the general reporting requirements under Form 5471 which was followed by the second article of this series about the reporting requirements of “Category 2 Filers”, which are the reporting requirements of a US citizen or resident who is an officer or director of a foreign corporation. This article will focus on the reporting requirements of “Category 3 Filers”, which are the reporting requirements that are generally triggered when US persons acquire and dispose of stock in a foreign corporation.

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G-IV Visas: Taxation on US Source Capital Gains

An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien even though the individual may live in the US for an extended period of time. Generally, nonresident aliens are not subject to US capital gains tax with the exception of real property located in the US. However, there is an exception to this rule for nonresident aliens who have been in the US for more than 182 days in a given year.

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FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE SECOND IN A SERIES ABOUT OTHER US TAX SURPRISES – REPORTING REQUIREMENTS – IRS FORM 5471 – Category 2 Filers

US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules.  The first article of this series provided the general reporting requirements under Form 5471.  This article will focus on the reporting requirements of “Category 2 Filers”, which are the reporting requirements of…

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G-IV Visas: Exclusion from Capital Gains Tax on the Sale of Principal Residence

An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien, even though the individual may live in the US for a number of years and even have his/her principal residence here.  Generally, when individuals who meet certain requirements sell their principal residences, they receive an exclusion…

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US signs Bilateral FATCA Agreements

Thanksgiving was quite a feast for the US Treasury Department. On November 26, 2013, the US and Costa Rica signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA) and on November 28, 2013, the US and the Cayman Islands signed a bilateral agreement to implement FATCA. The Costa Rican agreement is…

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Shifting Profits From the U.S. to Lower-Tax Jurisdictions – Opportunities Persist

As we approach the end of 2013, with the House scheduled to be in session for less than three more weeks this year, it appears highly unlikely that we will see any comprehensive U.S. tax reform in 2013.  This provides numerous opportunities for taxpayers, because many techniques for tax minimization are likely to remain available,…

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FILING US TAX RETURNS AND FBAR ISN’T THE WHOLE STORY: INTRODUCING IRS FORM 5471

US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you have no US source income.  Well, that’s not all.  This is the first in a series…

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