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Tag Archive for Tax Treaties

IRS Taxes For U.S. Inpats – What You Need To Know

Hugo Lesser

Inpats, or inpatriates, are foreigners who have been transferred to work in the United States. So in a sense, inpats are also (from the perspective of their country of origin) expats.

As individuals working in the States, inpats normally become subject to the U.S. taxation system. This is probably the first time they’ll encounter the IRS, who from their side refer to inpats as Resident Aliens. Read more

Do Tax Treaties Protect Expats From Double Taxation?

American citizens and green card holders, including people who have the right to U.S. citizenship, are required to file a federal income tax return each year declaring their worldwide income, wherever in the world they live. They may also have to pay U.S. taxes.

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Hale Stewart’s Webinar On Tax Treaties – May 23, 2017

Hale Stewart

Today, more and more companies’ and individuals’ tax matters cross borders. These multi-jurisdictional transactions and structures are typically governed by tax treaties. Although there are three basic model treaties (the OECDs, the US’ and the UNs), each uses many of the same concepts.

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Approval Process Of International Tax Treaties By United States

Tom Kerester

Foreign countries across the world have intricate tax treaties with the United States, which include topics such as exchanging tax information with tax authorities. In order for these tax treaties to come to fruition, they must first pass through the Executive and Legislative Branches of the U.S. Government for approval.

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Part 1: Tax Treaties, Determining “Tax Residence” And New OECD Common Reporting Standard

An article from Stikeman Elliot includes the following:

For CRS purposes, the term ‘reportable person’ generally refers to a natural person or entity that is resident in a reportable jurisdiction (excluding Canada and the United States) under the tax laws of that jurisdiction, or an estate of an individual who was a resident of a reportable jurisdiction under the tax laws of that jurisdiction immediately before death, other than: (i) a corporation the stock of which is regularly traded on one or more established securities markets; (ii) any corporation that is a related entity of a corporation described in clause (i); (iii) a governmental entity; (iv) an international organization; (v) a central bank; or (vi) a financial institution. See definitional subsection ITA 270 (1).

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Rental Property In Foreign Countries – A Primer!

I keep saying this, “The world is shrinking!”, ad nauseum perhaps, but I just cannot seem to get over that. When I went into the tax profession 15 years ago, I never thought I’d be reading as many tax treaties as I do now! I found out that the US had a Tax Treaty with Ukraine this year! Go figure!

Speaking of a shrinking globe, Inter-Governmental Agreements and Tax Treaties, it was uncanny this tax season, I had more than my share of clients who had a property or two in foreign countries by way of an inheritance or purchase and after having held it for a while as investments, they were now contemplating turning them into rentals.

I had written about owning foreign real estate a few blog-posts ago. You can read Read more

United States Corporations With Foreign Shareholders? Form 5472 – Part I

The United States market is a promising one for foreign investors and companies, but complicated issues must be addressed to avoid fines and penalties. One of these issues involves the completion of Form 5472.

US companies that are at least 25% owned by non-US shareholders and foreign companies that are engaged in a US trade or business must disclose information to the IRS on this somewhat confusing form. The IRS uses Form 5472 in developing information about the company and its related parties. Information provided on the form helps the IRS identify potential audit issues. Certain information on the Form 5472 might raise bright red flags for the IRS, too. Read more