New Disclosure Requirements for US LLCs and other Business Entities owned by Non-US Persons

On 13 December 2016, the Department of Treasury and Internal Revenue Service (“IRS”) issued final regulations creating reporting and record keeping requirements for US disregarded entities owned by non-US person. A disregarded entity is any entity with a single owner and is disregarded from its owner for US tax purposes.  The IRS realized that US…

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IRS Proposes Changes to Reporting Requirements for Foreign Owned US Disregarded Entities

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…

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US

The article was first published in  Global Tax Weekly, issue 170. Below is the full text of the seventh article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US by Stephen Flott, Omar Saleh, and Louisa…

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US Tax Compliance and Planning – The Offshore Voluntary Disclosure Program (OVDP)

By: Joseph Siegmann, and The Internal Revenue Service (IRS) created the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Domestic Offshore Procedure (SDOP) to encourage taxpayers to disclose foreign accounts and income that were subject to reporting but were not previously reported to the IRS. While both the OVDP and SDOP encourage taxpayers to disclose…

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits II

The article was first published in Global Tax Weekly, issue 160. Below is the full text of the fourth article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits II  by Stephen Flott, Christopher Krug, and Brittany Oravec,…

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits I

The article was first published in Global Tax Weekly, issue 159. Below is the full text of the third article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – Foreign Tax Credits I by Stephen Flott, and Brittany…

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Some Surprising Tax Changes Buried in the Fixing America’s Surface Transportation Act

On Friday, December 4, 2015, President Obama signed the “Fixing America’s Surface Transportation Act” (FAST Act) into law.  Although the FAST Act is primarily a transportation infrastructure bill, it contains tax provisions that could significantly impact US taxpayers living abroad. Section 32101 authorizes the Department of Treasury to advise the Secretary of State of the…

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – The Foreign Earned Income Exclusion

The article was first published in Global Tax Weekly, issue 156. Below is the full text of the second article in the series on US taxes for US persons living outside the US. US Tax Compliance  And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – The Foreign Earned Income Exclusion by…

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