Since October we have been writing a series of articles for Global Tax Weekly on the subject of the US Shipping Tax. Below is the full text of the fourth article. You may also download the article here . This is the fourth in a series of articles on US taxation of income from the…
DetailsSince October we have been writing a series of articles for Global Tax Weekly on the subject of the US Shipping Tax. Below is the full text of the third article. You may also download the article here. This is the third in a series of articles on US taxation of income from the transportation…
DetailsSince October we have been writing a series of articles for Global Tax Weekly on the subject of the US Shipping Tax. Below is the full text of the second article. You may also download the article here. US Taxation of Income from International Shipping – Sourcing Rules This is the second in a series…
DetailsSince October we have been writing a series of articles for Global Tax Weekly on the subject of the US Shipping Tax. Below is the full text of the first article. You may also download the article here. US Taxation Of Income From International Shipping And Offshore Activities This is the first in a series…
DetailsFurther to our June 8th, 2014 email regarding the June 3rd, 2014 announcement by the Commissioner of the Internal Revenue Service that changes to the Offshore Voluntary Disclosure Program (OVDP) and Streamlined Compliance Procedure (SCP) were under development, we are pleased to report that yesterday, the Service published changes to the SCP that substantially improve…
DetailsOne of the most widely-utilized tools by high net worth individuals to avoid U.S. estate and gift taxes, namely, “zeroed out GRATs,” remains available. This is due to the failure of Congress to adopt pending proposals to shut it down. “GRAT” stands for “grantor retained annuity trust.” GRATs have a long history of use to…
DetailsThe US taxes its citizens and residents based on their worldwide income. A US citizen living abroad can elect to exclude a certain amount of foreign earned income on his or her US income tax return, if certain requirements are met. For 2013, the maximum foreign earned income exclusion (“FEIE”) amount is $97,600 per taxpayer (amount indexed for inflation each year). The FEIE is available only to exclude income from wages or self-employment income earned for services performed outside the US. The FEIE is claimed on IRS Form 2555.
DetailsOn January 10, 2014, the US and Italy entered into a bilateral agreement for the implementation of FATCA The Italian agreement is based on the Model 1A treaty and requires Italian financial institutions to report their US account holders to the Italian government, which in turn will report those accounts to the US government. Similarly,…
DetailsAn individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien, even though the individual may live in the US for a number of years and even have his/her principal residence here. Generally, when individuals who meet certain requirements sell their principal residences, they receive an exclusion…
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…
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