Defining Intellectual and Intangible Property

Before delving headfirst into the taxation of intellectual property, it is important to understand what constitutes intellectual property and how it relates to intangible property. Intangible property is any property that has no physical substance, and intellectual property is intangible property created by individual(s). While these terms are often used interchangeably, some types of intangible…

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FinCen further delays FBAR filing requirement for certain accounts

After publishing final rules regarding people reporting their signature authority over foreign financial accounts, the Financial Crimes Enforcement Network (FinCen) received questions and comments about reporting for certain types of accounts. In response FinCen delayed the reporting requirement for individuals with signature authority over these types of accounts until June 30, 2012.  The most problematic…

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Relinquishment Success!

Recently, Flott & Co. assisted a client apply for a Certificate of Loss of Nationality of the United States (“CLN”) based on his relinquishment of US citizenship in 1984. He has now succeeded in obtaining an official CLN from the US Department of State, showing that he ceased being US citizen as of March 1984.…

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Better Department of State Guidance Needed for Contested Certificate of Loss of Nationality Applications

Flott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised.  Specific guidance is needed for cases when former US citizens living abroad wish to establish that they relinquished their US citizenship at a date in the past and a Consular…

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State Department Forms Need to Distinguish Between Relinquishment and Renunciation

These publications do not constitute legal advise.  Further information regarding this notice. Confusion at two US Consulates in Canada during recent relinquishment cases initiated by Flott & Co. clients revealed the need to develop forms and documents for use in establishing the intentional loss of US citizenship in the past. The current form, Form DS-4079,…

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