Does investing in a PFIC make sense given FATCA reporting?

September 2017

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision.  PFICs are reportable investments and their tax regime is punitive.  Under FATCA, US Taxpayers’ undisclosed foreign financial holdings are available to IRS through

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FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?

August 2017

In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application https://www.jdsupra.com/legalnews/fatca-fcpa-aml-and-ofac-allow-the-us-to-22658/  

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Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

August 2017

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful.  The definition of “Willful” or “non-willful” in Taxpayer’s conduct makes a big difference in how civil or

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Do you know about FATCA international payments?

July 10, 2017

  • South Florida Legal Guide/Miami Herald Business Monday

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

July 2017

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting.  PFIC computations are challenging for a Taxpayer in an amnesty program

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International Noncompliance

June 5, 2017

  • South Florida Business Journal Supplement to the Miami Herald Business Monday

Do You know that the US might have a Tax Sharing Information Agreement with your Country?

May 2017

The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents.  There are currently 43 countries on the list.  Exchange of

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Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

May 2017

FATCA is Chapter 4 of the Internal Revenue Code (IRC).   It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government.  To enforce its conscription, it contains a mechanism for financially penalizing FFIs that

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US Banks wanting to be ahead of the FATCA game must master international tax compliance

May 2017

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks with respect to outbound payments. Many of the

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The U.S. a tax haven? Could be questionable going forward given the new scrutiny of disregarded entities……

May 8, 2017

  • Miami Herald Business Monday - South Florida Legal Guide Supplement

Debit cards, Offshore Funds and a John Doe Summons

April 2017

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs.  It pursues cases in all jurisdictions of the world.  Over the years, numerous individuals have been identified as evading US taxes by hiding income in

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