The Tax Court’s decision in Toso v. Commissioner, was a mixed bag for taxpayers as it relates to Passive Foreign Investment Corporations (PFICs). The taxpayer argued that for purposes of extending the statute of limitations for assessment from 3 to 6 years under section 6501(e)(1)(A)(i) income taxed under section 1291 was not part of “gross…
DetailsThe Department of Justice (DOJ) announced that banker Adrian Baron of Loyal Bank Ltd. pleaded guilty to “conspiring to defraud the United States by failing to comply with the Foreign Account Tax Compliance Act (FATCA). According to court documents, Mr. Baron conspired with an undercover agent to conceal the undercover agent’s ownership of accounts opened…
DetailsOn 13 December 2016, the Department of Treasury and Internal Revenue Service (“IRS”) issued final regulations creating reporting and record keeping requirements for US disregarded entities owned by non-US person. A disregarded entity is any entity with a single owner and is disregarded from its owner for US tax purposes. The IRS realized that US…
DetailsInternal Revenue Bulletin 2016-21, issued May 23, 2016, by the Internal Revenue Service (IRS) and Treasury Department included a notice of proposed rulemaking altering the reporting requirements for US disregarded entities owned by non-US persons or entities. A US disregarded entity is an entity with a single owner that is not treated as separate from…
DetailsThe article was first published in Global Tax Weekly, issue 174. Below is the full text of the eighth article in the series on US taxes for US persons living outside the US. by Stephen Flott, and Omar Saleh, Flott & Co. PC This is the eighth article in a series of articles on key US…
DetailsThe article was first published in Global Tax Weekly, issue 163. Below is the full text of the fifth article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – FBAR by Stephen Flott, and Natalia Kosyak,…
DetailsThe article was first published in Global Tax Weekly, issue 160. Below is the full text of the fourth article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits II by Stephen Flott, Christopher Krug, and Brittany Oravec,…
DetailsThe article was first published in Global Tax Weekly, issue 159. Below is the full text of the third article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits I by Stephen Flott, and Brittany…
DetailsThe article was first published in Global Tax Weekly, issue 156. Below is the full text of the second article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – The Foreign Earned Income Exclusion by…
DetailsThe article was first published in Global Tax Weekly, issue 154. Below is the full text of the first article in the series on US taxes for US persons living outside the US. United States Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – An Overview by Stephen Flott…
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