Internal Revenue Bulletin 2016-21, issued May 23, 2016, by the Internal Revenue Service (IRS) and Treasury Department included a notice of proposed rulemaking altering the reporting requirements for US disregarded entities owned by non-US persons or entities. A US disregarded entity is an entity with a single owner that is not treated as separate from…
DetailsThe Net Investment Income Tax (NIIT) went into effect January 1, 2013, affecting tax years beginning on or after January 1, 2013. The NIIT applies to US persons with modified adjusted gross income above the following thresholds: $125,000 for filing status married filing separately; $200,000 for filing status single or head of household; and $250,000…
DetailsUS persons who have 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; the second article of this series about the reporting requirements of “Category 2 Filers”, which are the…
DetailsUS 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…
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…
DetailsUS 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…
DetailsUS 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…
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