The Tax Court’s decision in Toso v. Commissioner, was a mixed bag for taxpayers as it relates to Passive Foreign Investment Corporations (PFICs). The taxpayer argued that for purposes of extending the statute of limitations for assessment from 3 to 6 years under section 6501(e)(1)(A)(i) income taxed under section 1291 was not part of “gross…
DetailsOn 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…
DetailsInternal 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 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…
DetailsThe article was first published in Global Tax Weekly, issue 167. Below is the full text of the sixth article in the series on US taxes for US persons living outside the US. The US Foreign Account Tax Compliance Act by Stephen Flott, and Flott & Co. This is the sixth article in a series of…
DetailsThe article was first published in Global Tax Weekly, issue 163. Below is the full text of the fifth 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 – FBAR by Stephen Flott, and Natalia Kosyak,…
DetailsBy: 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…
DetailsThe 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,…
DetailsThe 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…
DetailsOn 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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