Presentation on “US TAXATION OF INTERNATIONAL SHIPPING”
Seminar on The US Taxation Of International Shipping offered by Stephen Flott, Esq. on November 7th and 8th, 2013 to the Dexter House in London.
US and France sign Bilateral FATCA Agreement
On November, 14 2013, the US and France signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). The agreement is based on the Model 1A treaty and requires French financial institutions to report US account holders to the French government, which will then report those accounts to the US. Similarly, US financial institutions are required…
DetailsTaxation of Forgein Nationals in the US on G-IV Visas
The United States imposes different types of taxes, including income and estate and gift taxes. An individual’s tax liability to the US government depends on whether the individual is a US citizen or resident or a nonresident alien. US citizens and residents are taxed on their worldwide income for US income tax purposes and on…
DetailsSubpart F Inclusions are not a Dividend
Rodriquez v. Commissioner, No. 12-60533 (July 5, 2013), aff’g 137 T.C. 14 (2011) ruled recently on whether inclusion of income under sections 951 and 956 (951 Inclusions) of the Internal Revenue Code (IRC) may qualify for the preferential tax treatment afforded to qualified dividends, as defined by section 1(h)(11) of the IRC. The Fifth Circuit…
DetailsNonresident Aliens and US Gambling Winnings
The IRS applies different methodologies for calculating the gambling winnings of US taxpayers and Nonresident Aliens (NRAs). For US taxpayers, the IRS calculates earnings based on winnings over the course of a gambling session, while for NRAs the IRS has taken the position that gambling winnings should be calculated based on each bet. So, for…
DetailsWhen a Trust is not a Trust: Mexican Land Trusts and US Tax Compliance
US persons are required to file Form 3520 if they create, transfer money to, receive distributions from, or are the owners of a foreign trust. While there is no tax liability associated with Form 3520, it is a complicated form and can be quite time consuming and expensive to prepare. As such, people avoid filing…
DetailsFBAR eFile Requirement
On February 29, 2012 the Financial Crimes Enforcement Network’s (FinCen) published rules requiring the E-Filing of all Bank Secrecy Act (BSA) submissions. As of July 1, 2013, FinCen’s regulations require that all FBARs be filed electronically through the BSA E-File System. The E-File system is not difficult to navigate and the electronic FBAR is a…
DetailsDefining 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…
DetailsUS signs new bilateral agreements to implement FATCA
On December 3, 2012, the US and Switzerland initialed a bilateral agreement to implement Foreign Account Tax Compliance Act (FATCA) (the agreement must still be approved by the Swiss Parliament). Previously, on November 20, 2012, Spain announced that it had agreed to a bilateral agreement implementing FATCA and on November 19, 2012, the IRS announced…
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