Citizenship Article Series: US Birthright Citizenship

During 2012, the tax consequences of U.S. citizenship became a major source of worry for U.S. citizens living in Canada. Widespread reports in the media of increased U.S. enforcement of the tax and financial account reporting obligations of U.S. citizens living outside the United States created considerable anxiety. They also spurred questions about the particulars…

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Parent Trap: Disclosure requirements of children with signatory authority over foreign accounts

While it is uncommon for parents in the US to grant their minor children signatory authority over  bank accounts, in other countries it is common practice to avoid inheritance, transfer taxes, or for other reasons. While this is generally not a problem, it can become an issue when the Internal Revenue Service (IRS) becomes involved.…

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The Inventor and the Tax Code

Section 1235 of the Internal Revenue Code (IRC) permits holders (Creators) “whose efforts created” the patent or holders (Investors) “who [] acquired [their] interest in such property in exchange for consideration in money or money’s paid to the creator prior to actual reduction to practice of the invention” to treat the transfer of “property consisting…

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FATCA: final regulations clarify the definition of depository accounts

The Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions and US persons who hold certain foreign accounts to report these accounts to the US. One of the most common types of account that must reported is the depository account. However, the definition of depository account changed significantly from the proposed regulations to the final regulations.

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Defining 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…

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