Foreign Trusts - John Richardson

TaxConnections is posting this thoughtfully written comment on an article titled “Treasury Exempts Applicable “Tax-Favored Foreign Trusts” From The Form 3520… And Therefore Form 3520A Requirement” written by John Richardson. Here is a recommendation for Treasury to consider as posted by a David Johnstone.

Excellent post. Based on my reading of the Revenue Procedure, as well as feedback from practitioners in the UK or Australia, I have grave reservations about the claim that this Revenue Procedure will help “many” Americans abroad. Perhaps this is an example of an attempt to simplify things from a legal perspective that in practice – once one does the math – may lead to greater complexity and help a very small number of people at best.
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William Byrnes

The IRS released Revenue Procedure 2017-21, which contains the updated withholding foreign partnership (WP) agreement and withholding foreign trust (WT) agreement.

The revenue procedure provides information on submitting an application or request for renewal of a WP or WT agreement.

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Ron Marini

Revenue Procedure 2016-57 replaces Fast Track Mediation (as outlined in Rev. Proc. 2003-41) with Fast Track Mediation—Collection. Revenue Procedure 2016-57 will be in 2016-49, dated December 5, 2016

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The Internal Revenue Service has just issued Revenue Procedure 2014-10 which provides guidance to foreign financial institutions (FFIs) entering into an FFI agreement with the IRS for FATCA (Foreign Account Tax Compliance Act) purposes. The final version of the FFI agreement is set forth in meticulous detail in the Revenue Procedure. The final FFI agreement contained in the Revenue Procedure contains a number of changes to provisions of the draft FFI agreement set out in an earlier IRS Notice (Notice 2013-69 2013-46 I.R.B. 503), on October 29, 2013.

Who Should Sign the FFI Agreement?

FFIs signing the FFI agreement will be treated as “participating FFIs”. Generally, these are Read More

According to IRS Revenue Procedure 2013-13 in addition to claiming the traditional office in home (OIH) or home office deduction on Internal Revenue Service Form 8829 there is a new simplified option now you can consider effective January 1, 2013. Basically this new simplified method if selected allows you to claim essentially a “standard deduction” of $5 per square foot up to 300 square feet for the portion of the home that meets the normal OIH limitations. There are some rules and of course advantages and disadvantages of each method so I’ve done some research comparing the traditional method and the new simplified method.

Under the traditional method

You calculate the square footage of the home used for business and maintain records of Read More