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Tag Archive for Form 5471

Tax Treaty Tiebreaker And Reporting: Forms 8938, 8621, 5471

John Richardson

Previously, we have look at the tax treaty tiebreaker and how it relates to taxation of Subpart F and PFIC income as well as eligibility for streamlined offshore procedures. This is another in a series of posts on the tax treaty tiebreaker (which is a standard provision in most U.S. tax treaties).

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Tax Treaty Tiebreaker And Taxation Of Subpart F And PFIC

John Richardson

Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on:

A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?)

B. His/her status under Title 26 (will he expatriate himself under Internal Revenue Code S. 7701(b)) and subject himself to the S. 877A “Exit Tax” provisions?

Now, on to the post

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Form 8621 And 5471 Are Required Even If The Tax Return Isn’t!

John Richardson

The Internal Revenue Code of the United States requires two things:

1. The calculation of taxes; and

2. The reporting of information.

The Internal Revenue Code of the United States is based on three basic principles:

1. A dislike of all things “foreign”. (If you see the word “foreign” a penalty is sure to follow.)

2. A hatred of all forms of non-U.S. “tax deferral”

3. An attempt to stop the “leakage” of “U.S. taxable assets” from the U.S. tax base. (Examples include the U.S. tax treatment of the “alien spouse” and the U.S. S. 877A “Exit Tax” that may be payable when one makes the decision to renounce U.S. citizenship).

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Tax Court Upholds Penalties On Expat’s Failure To Disclose

Ephraim Moss

In a new decision, the Tax Court upheld heavy penalties imposed by the IRS on a U.S. expat taxpayer who failed to report his ownership in two foreign corporations. The decision certainly serves as a cautionary tale for expats – the IRS is serious about foreign reporting and the U.S. court system has its back.

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Monday’s Tax Planning Seminar For CFCs In Philadelphia

Kat Jennings

September 19 is just on the other side of the weekend. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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September’s Tax Planning Seminar For CFCs In Philadelphia

Kat Jennings

September 19 is coming up fast. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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September’s Tax Planning Seminar for CFCs in Philadelphia

Kat Jennings

September 19 is coming up fast. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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Sign Up For September’s Tax Planning Seminar for CFCs in Philadelphia

Kat Jennings

September 19 is coming up fast. There’s not much time left to sign up for this Tax Planning Seminar.

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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Sign Up Today For Tax Planning Seminar for CFCs

Kat Jennings

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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Seminar – Tax Planning for CFCs – Philadelphia, PA

Kat Jennings

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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Tax Planning for CFCs Seminar—Philadelphia

Kat Jennings

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

Read more

Tax Planning for CFCs Seminar—September 19

Networking Seminars one day technical update on Tax Planning for CFCs under Subpart F Income. One of the purposes of Subpart F is to prevent CFCs from structuring transactions in a way that are designed to manipulate the inconsistencies between foreign and U.S. tax systems to inappropriately generate low or non-taxed income on which U.S. tax may be permanently deferred.

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