For many foreign persons, the U.S. tax system can be a complicated web of conflicting rules and exceptions, making compliance difficult, at best. One of the more complex challenges concerns the U.S.’s different treatment of foreign persons for income tax and estate and gift tax purposes. In general, the U.S. presumes foreign persons to be […]
Effective May 13, 2019, the IRS will only issue Employer Identification Numbers (EINs) to entities whose applications name a responsible party who has a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). No longer will the IRS accept Form SS-4 or online applications from entities that use their existing EINs to obtain additional […]
The Tax Cuts and Jobs Act (TCJA) has had broad-reaching impact on all taxpayers for 2018 and going forward. This includes U.S. persons who are beneficiaries of foreign non-grantor trusts. As a result of the TCJA suspending the deduction for miscellaneous itemized deductions, which includes the deduction for investment management fees, trust distributable net income […]
Sept. 28, 2018, marked the end of the IRS’s Voluntary Offshore Disclosure Program (OVDP), which provided reticent taxpayers with protection from criminal prosecution and an opportunity to pay reduced penalties when they came forward to report and pay taxes on unreported foreign income and assets. As a result, the IRS has put into place new, […]
Commercial and residential real estate in the U.S. continues to be a safe haven for foreign investors who seek the potential for higher yields and capital preservation than they may receive in their home countries or from portfolio investments. However, the potential upside from an investment in the U.S. real estate market comes with the […]
Due to global efforts to combat tax avoidance and uncover assets hidden in offshore accounts, individuals and financial institutions continue to face a complex and challenging environment for cross-border tax reporting and compliance. There are presently more regulations centered on tax transparency and reducing countries’ lost tax revenues than ever before. However, there remains a […]
U.S. citizens and resident aliens who live in areas affected by Hurricane Irma will receive an extension of time to report their financial interest in or signature authority over foreign bank, securities or other financial accounts with an aggregate value exceeding $10,000 during any time in 2016. The Financial Crimes Enforcement Network (FinCEN) announced […]
As Congress shifts its attention from healthcare to tax reform, key Republicans and the White House on July 27, 2017, issued a joint statement agreeing to “set aside” a proposed and much-hyped border adjustment tax (BAT) on imported goods. Business groups that feared a destination-based tax would drive up costs cheered this news. However, it […]