FILING US TAX RETURNS AND FBAR ISN’T THE WHOLE STORY: INTRODUCING IRS FORM 5471

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…

Details

US and France sign Bilateral FATCA Agreement

On 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…

Details

IRS Publishes new Method for Non-Foreign Financial Entities to Comply with FATCA

On 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,…

Details

Accidental Americans and US Tax Compliance: A Discussion with the IRS

Flott & Co. recently had the opportunity to discuss our proposal for changes to the existing IRS “noisy” disclosure programs (Offshore Voluntary Disclosure Program – OVDP – and the Streamlined Filing Compliance Procedure for Non-Resident US Taxpayers – Streamlined Process) with representatives of the Service.  The discussion focused on encouraging the IRS to create a…

Details