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Tag Archive for FATCA

Top Tax Blogs from 2015

Top Tax Blogs from 2015

During 2015 readers of TaxConnections Worldwide Tax Blogs arrived from more than 200 countries and spent an average of 12:45 during each visit. These are mighty numbers and they are due to the tax experts who joined our community and submitted their tax expertise and blog posts throughout the year.

We would like to congratulate our top tax blog contributors and link you to the top posts this year. We are grateful for the journey we made with you throughout the year and look forward to enjoying a successful 2016 with you.

Check out the top 20 Tax Blogs in 2015!

Story of A Good Citizen Who Reports Foreign Bank Accounts But Forgets FBARs! Huh? – Manasa Nadig

How To Live Outside The United States In An FBAR And FATCA World – John Richardson

Read This Before Tossing Old Tax Records – Barry Fowler

Read more

Streamlined Program Will Expire!

TaxConnections Member Larry Stolberg

The updated Streamlined Program that was revised in June 2014 is a simplified method of allowing delinquent U.S. taxpayers to become tax compliant. If certain conditions are met, tax and information return penalties could be waived. Refer to my article on the website and the IRS site for additional information on the program.

On December 17th at the George Washington University Law conference on international taxation, the Commissioner of the IRS John Koskinen said, “At some point, we will have assumed that people have had enough notice that they should have become voluntarily compliant,” “At that point—after some period of time and you’re not compliant—it will be assumed that logically you are purposely not compliant”. Read more

Form 1042 – IRS Makes Some Important Changes

Pallav Acharya5

Last month IRS made changes to the instructions of Form 1042 – Annual Withholding Tax Return for US Source Income of Foreign Persons. As the readers may recall, IRS made some changes to Form 1042 earlier to coincide with the newly issued FATCA regulations under Chapter 3 and 4. The updated instructions were released to assist the withholding agents in preparing the Form. It is pertinent to note that although 2014 and 2015 versions of the Form are identical, IRS has made certain parts of the Form which were optional in 2014, as mandatory for 2015.

Following parts of Form 1042-S are accordingly mandatory for 2015:

• Withholding agent’s Chapter 3 and 4 status code must be entered on page 1 under the withholding agent’s name. Read more

Part 15 – Understanding “Exit Taxes”

John Richardson 24
Interview with GordonTLong.com – Citizenship based taxation, PFIC, the S. 877A Exit Tax and #Americansabroad

On May 22, 2015 I was interviewed by Gordon T. Long. There is NO way to discuss U.S. “citizenship taxation” (which is primarily “place of birth taxation”) without discussing the S. 877A Exit Tax rules. During the month of April 2015, I wrote a 14 part series on “How the S.877A rules affect Americans abroad“. The interview with Mr. Long serves as a good reminder (or if you don’t want to read the posts) on:

– what it means to be a “covered expatriate

how the U.S. S. 877A “Exit Tax” rules operate to impose punitive “taxation” on non U.S. pensions (See the actual Read more

Part 11 – Understanding “Exit Taxes”

John Richardson 20
S. 2801 of the Internal Revenue Code is NOT a S. 877A “Exit Tax”, but a punishment for the “sins of the father”

Updated September 12, 2015 – the IRS has issued “proposed rules”  governing the issue of “The sins of the father”.

The following was a comment on Part 9 of this “Exit Tax” series.

“I know many tax compliant, patriotic Americans who have renounced. Many have done so seeing the $2m threshold approaching, to protect their families and get on with their lives. All with heavy hearts.

You did not mention the additional burden on those who renounce who have US citizen relatives–the tax their Read more

Part 10 – Understanding “Exit Taxes”

John Richardson 19
The S. 877A “Exit Tax” and possible treaty relief under the Canada US Tax Treaty

Introduction – The Canada U.S. Tax Treaty Does Not Always Prevent Double Taxation

See: Part 9 – Understanding “Exit Taxes” – For #Americansabroad: US “citizenship taxation” is “death by a thousand cuts”, but the S. 877A Exit Tax is “death by the guillotine”.

When countries independently make major changes in tax law, double taxation can occur.

The following comment from 5thSwiss on the Isaac Brock Society site explains why and how double taxation can be a reality. It also underscores the dangers of a U.S. citizen leaving the United States. Read more

Unprecedented Success for US Offshore Amnesty Programs!

Ronald Marini picture31

According to the Internal Revenue Service:

Since OVDP Began in 2009, There Have Been > 54,000 Disclosures!
The IRS has collected > $8 Billion.

We previously discussed this in our post “Offshore Compliance Programs Generate $8 Billion” However, the figures have risen sharply since the IRS’ last progress report in January this year, when it announced that the OVDP schemes had attracted 54,000 disclosures and USD7 billion in tax.

It is believed that most of the additional 30,000 taxpayers who have volunteered since then, have been attracted by the ‘streamlined’ program launched in June 2014 for ‘non-wilful’ taxpayers. This program originated from the IRS’ Read more

Offshore Compliance Programs Generate $8 Billion

Ronald Marini picture29
IRS Urges People to Take Advantage of Voluntary Disclosure Programs… You Think?

The IRS released IR-2015-116 on Oct. 16, 2015, to remind U.S. taxpayers with undisclosed offshore accounts, that with more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, they should strongly consider existing paths established to come into full compliance with their federal tax obligations.

Both the Offshore Voluntary Disclosure Program (OVDP) and the streamlined procedures enable taxpayers to correct prior omissions and meet their federal tax obligations while mitigating the potential penalties of continued non-compliance. There are also separate procedures for those who have paid their income taxes but omitted Read more

IRS Offers FATCA Guidance For Trusts & Partnerships

TaxConnections

The IRS posted FAQ’s today on the effective dates of FATCA agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts.

Qualified Intermediaries: Withholding Foreign Partnerships/ Withholding Foreign Trusts

Q1. How does a Financial Institution that is not currently a Qualified Intermediary (“QI”), a Withholding Foreign Partnership (“WP”), or a Withholding Foreign Trust (“WT”) register to become one?
Q2. How do FIs that are currently QIs, WPs and WTs renew their agreements?
Q3. I am not currently a QI/WP/WT.  Can I use the LB&I registration portal to register for Read more

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