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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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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Flott & Co Suggestion for New FBAR Compliance Procedure

Our 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…

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