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 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…
DetailsIn late May, the IRS published the first list of the Foreign Financial Institutions (“FFI”) that have applied for and received Global Intermediary Identification Numbers (“GIIN’s”). The list is searchable at the IRS website. According to the IRS, the list will be periodically updated. Recipients of W-8BEN-E’s are now able to independently verify whether an FFI that…
DetailsThe Net Investment Income Tax (NIIT) went into effect January 1, 2013, affecting tax years beginning on or after January 1, 2013. The NIIT applies to US persons with modified adjusted gross income above the following thresholds: $125,000 for filing status married filing separately; $200,000 for filing status single or head of household; and $250,000…
DetailsYou may have seen a post like the one below and concluded that the IRS had eased FATCA enforcement for everyone. That is NOT true. During the American Bar Association Section of Taxation meeting in Washington, DC from May 8th through 10th, senior officials of the IRS explained that the announcement made public on Friday, May…
DetailsCompensation clawbacks, where employers recoup compensation, e.g., incentive bonuses, to rectify violations of rules or policies, have received much press since the Great Recession of 2008, and a number of well-publicized financial scandals, such as the J.P. Morgan “London Whale” incident. The Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) (“Dodd-Frank”) dramatically increased the incidents of clawbacks, and, thus, the importance of their federal income tax treatment
DetailsLast Thursday the IRS published an FBAR Reference Guide that clients will find helpful in explaining various aspects of the Foreign Bank Account Reporting regime, including key definitions and requirements. FBARs for 2013 are due no later than 30 June 2014 and must be filed electronically. Paper forms are no longer accepted. There is no…
DetailsOn March 28, 2014, the IRS released the final version of the W-8BEN-E. The W-8BEN-E is an important step in enforcing FATCA, and replaces the W-8BEN for non-US entities receiving payments from US payors. The purpose of the W-8BEN-E for non-US entities to certify their FATCA status. However, it is still the responsibility of the US payor to request the…
DetailsLast Wednesday, the US Treasury and IRS announced that jurisdictions that have reached agreements in substance with the US on the provisions of intergovernmental agreements under the Foreign Account Tax Compliance Act (“FATCA”) will be treated as having agreements in effect until December 31, 2014.
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