US 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.
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you have no US source income. Well, that’s not all. This is the first in a series…
DetailsOn 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…
DetailsOn October 29, the IRS published Notice 2013-69 (the Notice) which provides guidance to Foreign Financial Institutions (FFI’s) seeking to enter into FFI Agreements with the Internal Revenue Service (IRS) to comply with their Foreign Account Tax Compliance Act (FATCA) obligations. While the majority of the Notice is dedicated to providing a draft FFI Agreement,…
Detailshttp://www.flottco.com/doingbusinessacrossborders//wp-content/uploads/2014/06/IRS-LBI-Horton-re-New-Tax-Compliance-Proposal.pdf
On July 12, 2013, the US Treasury Department issued Notice 2013-43 which extended the implementation deadline of most FATCA rules for an additional six months. This has moved the general implementation deadline for FATCA from January 1, 2014 to July 1, 2014. Still, US persons holding foreign accounts will be impacted by FATCA sooner rather…
DetailsRodriquez v. Commissioner, No. 12-60533 (July 5, 2013), aff’g 137 T.C. 14 (2011) ruled recently on whether inclusion of income under sections 951 and 956 (951 Inclusions) of the Internal Revenue Code (IRC) may qualify for the preferential tax treatment afforded to qualified dividends, as defined by section 1(h)(11) of the IRC. The Fifth Circuit…
DetailsUS persons are required to file Form 3520 if they create, transfer money to, receive distributions from, or are the owners of a foreign trust. While there is no tax liability associated with Form 3520, it is a complicated form and can be quite time consuming and expensive to prepare. As such, people avoid filing…
DetailsThe Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions and US persons who hold certain foreign accounts to report these accounts to the US. One of the most common types of account that must reported is the depository account. However, the definition of depository account changed significantly from the proposed regulations to the final regulations.
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