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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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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FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: RULES AND CATEGORIES FOR IRS FORM 5471

US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471. The rules and reporting requirements for each category of filer are unique and will be discussed in more detail in subsequent articles. Before describing the…

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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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US and France sign Bilateral FATCA Agreement

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…

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IRS Publishes new Method for Non-Foreign Financial Entities to Comply with FATCA

On 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,…

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