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…
DetailsBefore 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…
DetailsAfter publishing final rules regarding people reporting their signature authority over foreign financial accounts, the Financial Crimes Enforcement Network (FinCen) received questions and comments about reporting for certain types of accounts. In response FinCen delayed the reporting requirement for individuals with signature authority over these types of accounts until June 30, 2012. The most problematic…
DetailsOn 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…
DetailsThese publications do not constitute legal advise. Further information regarding this notice. Confusion at two US Consulates in Canada during recent relinquishment cases initiated by Flott & Co. clients revealed the need to develop forms and documents for use in establishing the intentional loss of US citizenship in the past. The current form, Form DS-4079,…
DetailsBy Ji Zhang, Esq., 2012/07/26 When foreign companies work through US subsidiaries to conduct business in the US, it can bring up complicated issues of who should be held responsible for the tax, and at what rate. For example, during years 2004-2007, DeCoro Limited (Parent), a Hong Kong limited liability company, manufactured furniture in China. DeCoro USA…
DetailsFLOTT & CO PC PRESENTATION ON THE US TAXATION OF INTERNATIONAL SHIPPING INCOME The Associates at Flott & Co PC, 2012/03/08 US Taxation of International Shipping Income from Flott & Co. PC Presentation on the US Taxation of International Shipping Income given to the 2nd Annual Marine Money London Ship Finance Forum by Flott & Co. PC on…
DetailsDebt obligations issued by the US government are defined as US property for estate tax purposes. Yet, what if you diversified your portfolio and have an US bank account? Would these things also count as it property within the US? It depends. Say you deposit $75,000 into ABC Bank, which is located in the US. …
DetailsThis seventh in a series of articles on the US taxation of shipping income explains the “look through” rule that applies to exemptions from the tax available pursuant to Section 883. The next article will explain what must be done to comply with the filing requirements associated with Section 883 exemptions. The tax on USSGTI…
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