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…
DetailsThe article was first published in Global Tax Weekly, issue 170. Below is the full text of the seventh 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 by Stephen Flott, Omar Saleh, and Louisa…
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…
DetailsAs we approach the end of 2013, with the House scheduled to be in session for less than three more weeks this year, it appears highly unlikely that we will see any comprehensive U.S. tax reform in 2013. This provides numerous opportunities for taxpayers, because many techniques for tax minimization are likely to remain available,…
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