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Internal Revenue Service › Reporting Requirements › Tax Treaty

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Katten Muchin Rosenman LLP

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations for Some US Taxpayers

Katten Muchin Rosenman LLP on

It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more

Freeman Law

Does a Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes”

Freeman Law on

Introduction - Much of the current litigation between taxpayers and the United States has centered on the definition of willfulness or whether the non-willful FBAR penalty should apply on a per year or per account basis. ...more

Patterson Belknap Webb & Tyler LLP

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

Patterson Belknap Webb & Tyler LLP on

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

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