We genuinely appreciate TaxConnections members for the important role they play in educating tax professionals and taxpayers on rules and regulations they surface in the IRS tax code. These treasures finds are very helpful to so many and in this case John Richardson identifies Guidance For Expatriate Under Section 877 2501 210 and
6039F known as IRS Notice 97-19. If you are an expatriate, this is an important IRS Notice for you to read.
Guidance For Expatriate Under Section 877 2501 210 and
6039F (Notice 97-19)
The Health Insurance Portability and Accountability Act of 1996
(the “Act”) recently amended sections 877, 2107 and 2501 of the Internal Revenue Code (the “Code”), and added new information reporting requirements under Section 6039F. This notice provides guidance regarding certain federal tax consequences under these sections and section 7701(b)(10) for certain individuals who lose U.S. citizenship, cease to be taxed as U.S. lawful permanent residents, or are otherwise subject to tax in the manner provided by section 877.
This notice has eleven sections:
Section I – General Application Of Sections 877 210 and 2501
Section II – Computing Tax Under Section 877
Section III – Tax Liability And Net Worth Tests
Section IV – Ruling Requests
Section V – Exchanges And Gain Recognition Agreements
Section VI – Contributions To Controlled Foreign Corporations
Section VII – Annual Information Reporting
Section VIII – Interaction With Tax Treaties
Section IX – Initial Information Reporting
Section X – Transition Provision
Section XI – Interaction With Section 7701(b)(10)
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