Final Version of W8-BEN-E Released: New FATCA Compliance Requirements for non-US Entities

On March 28, 2014, the IRS released the final version of the W-8BEN-E. The W-8BEN-E is an important step in enforcing FATCA, and replaces the W-8BEN for non-US entities receiving payments from US payors. The purpose of the W-8BEN-E for non-US entities to certify their FATCA status. However, it is still the responsibility of the US payor to request the…

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FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE THIRD IN A SERIES ABOUT OTHER US TAX SURPRISES – REPORTING REQUIREMENTS – IRS FORM 5471 – Category 3 Filers

US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided the general reporting requirements under Form 5471 which was followed by the second article of this series about the reporting requirements of “Category 2 Filers”, which are the reporting requirements of a US citizen or resident who is an officer or director of a foreign corporation. This article will focus on the reporting requirements of “Category 3 Filers”, which are the reporting requirements that are generally triggered when US persons acquire and dispose of stock in a foreign corporation.

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FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE SECOND IN A SERIES ABOUT OTHER US TAX SURPRISES – REPORTING REQUIREMENTS – IRS FORM 5471 – Category 2 Filers

US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules.  The first article of this series provided the general reporting requirements under Form 5471.  This article will focus on the reporting requirements of “Category 2 Filers”, which are the reporting requirements of…

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US signs Bilateral FATCA Agreements

Thanksgiving 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…

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FILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: RULES AND CATEGORIES FOR IRS FORM 5471

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…

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