Flott & Co.’s recent experience in assisting two former US citizens seeking formal documentation of their prior loss of US citizenship underscores the need for expanded guidance on the relinquishment of US citizenship in the US Department of State Foreign Affairs Manual (Volume 7 – Consular Affairs) (“FAM”). In cases that appear to have been…
DetailsFlott & Co.’s recent experience in assisting two former US citizens seeking formal documentation of their prior loss of US citizenship underscores the need for expanded guidance on the relinquishment of US citizenship in the US Department of State Foreign Affairs Manual (Volume 7 – Consular Affairs) (“FAM”). In cases that appear to have been…
DetailsFlott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies in the treatment of similar cases across the world by American consulates, more specific guidance and clearer procedural rules are needed for consular officers on the subject…
DetailsFlott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies in the treatment of similar cases across the world by American consulates, more specific guidance and clearer procedural rules are needed for consular officers on the subject…
DetailsBy Ji Zhang, Esq., 2012/07/26 When foreign companies work through US subsidiaries to conduct business in the US, it can bring up complicated issues of who should be held responsible for the tax, and at what rate. For example, during years 2004-2007, DeCoro Limited (Parent), a Hong Kong limited liability company, manufactured furniture in China. DeCoro USA…
DetailsIntroduction Under Guo Shui Fa (1996)(87), Guo Shui Han (2008)(952) and the revised Business Tax Law, China imposes a 4.25% outbound shiptax—consisting of 1.25% enterprise tax and 3% business tax—on foreign companies’ gross income from transporting goods and passengers out of China. Chinese ship agents are the withholding agents responsible for remitting the shiptax to…
DetailsAs part of National Small Business Week, I would like to discuss the JOBS (“Jumpstart Our Business Startups”) Act enacted on April 5th, 2012. It contains the “CROWDFUND” Act, which allows a new method of investment for start-up companies called “crowdfunding.” The term has been used colloquially for some time, usually in a charitable context,…
DetailsLast week, I introduced Section 892 regulations, which address the taxation of U.S. income earned by foreign governments. In a nutshell, Section 892 exempts foreign governments’ income from investing in U.S. stock, bonds and certain financial instruments; other types of income are not exempt. To prevent unwary governmentally controlled entities who inadvertently conducted a…
DetailsDebt obligations issued by the US government are defined as US property for estate tax purposes. Yet, what if you diversified your portfolio and have an US bank account? Would these things also count as it property within the US? It depends. Say you deposit $75,000 into ABC Bank, which is located in the US. …
DetailsThe recent surge in foreign government investing in the U.S. economy, particularly through Sovereign Wealth Funds, has prompted the Internal Revenue Services (“IRS”) to modify the existing Section 892 regulations regarding taxation of U.S. income earned by foreign governments. In a nutshell, Section 892 exempts foreign governments’ income from investing in U.S. stock, bonds and…
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