The 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…
DetailsOn February 29, 2012 the Financial Crimes Enforcement Network’s (FinCen) published rules requiring the E-Filing of all Bank Secrecy Act (BSA) submissions. As of July 1, 2013, FinCen’s regulations require that all FBARs be filed electronically through the BSA E-File System. The E-File system is not difficult to navigate and the electronic FBAR is a…
DetailsOn February, 14 2013, the US and Switzerland signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). In addition, on January 23, 2013, the US and Ireland signed their own bilateral agreement to implement FATCA. The US is averaging about one bilateral FATCA agreement signed per month. While this seems like…
DetailsThe Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions and US persons who hold certain foreign accounts to report these accounts to the US. One of the most common types of account that must reported is the depository account. However, the definition of depository account changed significantly from the proposed regulations to the final regulations.
DetailsBefore delving headfirst into the taxation of intellectual property, it is important to understand what constitutes intellectual property and how it relates to intangible property. Intangible property is any property that has no physical substance, and intellectual property is intangible property created by individual(s). While these terms are often used interchangeably, some types of intangible…
DetailsOn January 17, 2013, the Department of Treasury and the Internal Revenue Service (IRS) announced the release of the final FATCA regulations (Regulations). The Regulations become effective on January 28, 2013, and diverge significantly from the current temporary regulations. While there are numerous changes in the Regulations, we highlight just some of the significant changes:…
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