On November, 14 2013, the US and France signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). The agreement is based on the Model 1A treaty and requires French financial institutions to report US account holders to the French government, which will then report those accounts to the US. Similarly, US financial institutions are required…
DetailsOn October 29, the IRS published Notice 2013-69 (the Notice) which provides guidance to Foreign Financial Institutions (FFI’s) seeking to enter into FFI Agreements with the Internal Revenue Service (IRS) to comply with their Foreign Account Tax Compliance Act (FATCA) obligations. While the majority of the Notice is dedicated to providing a draft FFI Agreement,…
DetailsOur suggestion for a new compliance procedure for non-resident, dual national, delinquent us taxpayers is as follows: This compliance procedure is only available to US persons who are also nationals of another country and (1) have resided continuously outside the United States for more than ten years as of January 1, 2013 and continue to…
Detailshttp://www.flottco.com/doingbusinessacrossborders//wp-content/uploads/2014/06/IRS-LBI-Horton-re-New-Tax-Compliance-Proposal.pdf
The Affordable Care Act requires that all US taxpayers have health care that provides minimum essential coverage (MEC) after the 2013 calendar year. If a US taxpayer does not have the required MEC, the US taxpayer will be assessed a penalty for each month they do not have the required coverage. Most US taxpayers living…
DetailsRodriquez v. Commissioner, No. 12-60533 (July 5, 2013), aff’g 137 T.C. 14 (2011) ruled recently on whether inclusion of income under sections 951 and 956 (951 Inclusions) of the Internal Revenue Code (IRC) may qualify for the preferential tax treatment afforded to qualified dividends, as defined by section 1(h)(11) of the IRC. The Fifth Circuit…
DetailsThe IRS applies different methodologies for calculating the gambling winnings of US taxpayers and Nonresident Aliens (NRAs). For US taxpayers, the IRS calculates earnings based on winnings over the course of a gambling session, while for NRAs the IRS has taken the position that gambling winnings should be calculated based on each bet. So, for…
DetailsUS persons are required to file Form 3520 if they create, transfer money to, receive distributions from, or are the owners of a foreign trust. While there is no tax liability associated with Form 3520, it is a complicated form and can be quite time consuming and expensive to prepare. As such, people avoid filing…
DetailsWhile it is uncommon for parents in the US to grant their minor children signatory authority over bank accounts, in other countries it is common practice to avoid inheritance, transfer taxes, or for other reasons. While this is generally not a problem, it can become an issue when the Internal Revenue Service (IRS) becomes involved.…
Details