Does investing in a PFIC make sense given FATCA reporting?
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 its receipt of reports provided by Foreign Financial Institutions (FFI). US Taxpayers ought to consider […]
FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?
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. Following is FATCA, FCPA, AML and OFAC: FATCA: requires Foreign Financial Institutions to report information directly to IRS about financial accounts held by U.S. taxpayers or by certain […]
Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?
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 criminal penalties are assessed for unreported financial accounts and financial assets. If IRS identifies a […]
Do you know about FATCA international payments?
Do you know about FATCA international payments? was published by the South Florida Legal Guide.
Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!
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 such as the OVDP. There is a challenge due to the lack of historical information […]
International Noncompliance
International Noncompliance was published by the South Florida Legal Guide.
Do You know that the US might have a Tax Sharing Information Agreement with your Country?
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 Information (EOI) refers to sharing of tax-related information between two or more countries for tax […]
Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?
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 do not comply. Developing regulatory and administrative guidance to implement FATCA took more than four […]
US Banks wanting to be ahead of the FATCA game must master international tax compliance
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 individuals that are responsible for ensuring compliance with the rules applicable to the US Financial […]
The U.S. a tax haven? Could be questionable going forward given the new scrutiny of disregarded entities……
The U.S. a tax haven? Could be questionable going forward given the new scrutiny of disregarded entities…… was published by the South Florida Legal Guide.
Is the Perception That the US Continues to Be a Tax Haven a Reality?
Is the Perception That the US Continues to Be a Tax Haven a Reality? was published by the Daily Business Review on 4/26/17.
Debit cards, Offshore Funds and a John Doe Summons
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 offshore banks, brokerage accounts or nominee entities; using debit cards, credit cards or wire transfers […]
