Over 20 countries have joined the UK-led pilot to automatically share ownership information for companies. As such their tax and law enforcement agencies will now exchange data on company beneficial ownership registers and new registers of trusts enabling more effective investigation of financial wrongdoing and tax-dodging. [See free SSRN download of Lexisnexis® Guide to FATCA Compliance 2016] Read More
Is This Canadian Baby An American Tax Cheat?
A Canadian baby is learning about taxes, banking and activism at a tender age. The eight month old girl received a “Dear Valued Customer” letter from her Canadian bank when she was six months old advising her that her account information may be provided to Canada Revenue Agency to pass on to IRS. The wee “Valued Customer” was directed to complete, sign and mail forms to the bank.
Baby Elle (not her real name) and her Canadian parents were Read More
Tax Considerations When Dealing With Foreign Transactions
As a follow-up to questions, about tax considerations when dealing with foreign transactions , one of the big areas of concern is the area of foreign entities and the income effects that they have on our person tax returns. Controlled Foreign Corporations have a unique capability of delaying the paying of tax until the income is Read More
A leak of searchable 11.5 million files, that’s 2.6 terabytes of data, from the embattled offshore services provider Mossack Fonseca. Every email, client note, asset and income statement, instruction, communication, .. since 1977! 2.6 terabytes of data, 11.5 million files, is a lot of files and scanned documents to comb through, so this leak is potentially, and probably, more significant than the 2014 ICIJ reported on leak or even the HSBC and UBS’ leaks. Read More
A lot has been written about the Foreign Account Tax Compliance Act {FATCA} in the past year. As this year comes to a close and I write up this post, I wanted to give you all, my dear readers a synopsis at your finger-tips, a round-up, if you will of some major FATCA events for 2015:
1. FBAR Deadlines Changed:
On July 31, 2015 President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law, which modified the due date of several key forms for Americans with foreign income and Americans living abroad. That includes the Report of Foreign Bank and Financial Accounts, or Form 114, colloquially known as the FBAR.
Any U.S. person with a financial interest in, or signatory authority over, foreign financial accounts must file the FBAR, if at any time, the aggregate value of their relevant foreign account or accounts exceeds $10,000. An account over Read More
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
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
This is a problem that I have dealt with a couple of times (at least) in the last few months. Sooner or later your contributions (no later than the year you turn 71) must cease. At that point your RRSP (Registered Retirement Savings Plan) savings must be converted to income. A RRIF (Registered Retirement Income Fund) is a popular way to convert that RRSP to income.
Just remember that by creating a RRIF you are opening a new account and will be subject to the FATCA inquisition. U.S. citizenship creates planning problems to be solved!
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
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
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
Retained Tax Executive Search Services: When You Need An Expert On A Tax Executive Search For Your Organization
Certificates Of Discharge From IRS Liens
IRS Independent Office Of Appeals Forms Alternative Dispute Resolution Program Management Office
IRS Shifting More Attention Onto High Income Earners, Partnerships And Large Corporations Following Passage Of Inflation Reduction Act Funding
Exempt Non-resident Citizens From FBAR
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