On 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…
DetailsSince October we have been writing a series of articles for Global Tax Weekly on the subject of the US Shipping Tax. Below is the full text of the fourth article. You may also download the article here . This is the fourth in a series of articles on US taxation of income from the…
DetailsIn late May, the IRS published the first list of the Foreign Financial Institutions (“FFI”) that have applied for and received Global Intermediary Identification Numbers (“GIIN’s”). The list is searchable at the IRS website. According to the IRS, the list will be periodically updated. Recipients of W-8BEN-E’s are now able to independently verify whether an FFI that…
DetailsYou may have seen a post like the one below and concluded that the IRS had eased FATCA enforcement for everyone. That is NOT true. During the American Bar Association Section of Taxation meeting in Washington, DC from May 8th through 10th, senior officials of the IRS explained that the announcement made public on Friday, May…
DetailsMarch has started well in the Treasury Department’s ongoing efforts to implement FATCA. The Treasury Department inked two more FATCA intergovernmental agreements (IGA’s) on March 5, 2014. Importantly, Chile has signed an IGA, the first country in South America. The Finnish IGA agreement is based on the Model 1A treaty and requires Finnish financial institutions…
DetailsOn January 10, 2014, the US and Italy entered into a bilateral agreement for the implementation of FATCA The Italian agreement is based on the Model 1A treaty and requires Italian financial institutions to report their US account holders to the Italian government, which in turn will report those accounts to the US government. Similarly,…
DetailsThanksgiving 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…
DetailsUS 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…
DetailsSeminar on The US Taxation Of International Shipping offered by Stephen Flott, Esq. on November 7th and 8th, 2013 to the Dexter House in London.