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Reporting Requirements International Tax Issues

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

BakerHostetler on

Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Allen Barron, Inc.

US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen

Allen Barron, Inc. on

In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more

Foodman CPAs & Advisors

Alivio Del IRS Para Ciertos Documentos Internacionales Presentados Tarde

Foodman CPAs & Advisors on

El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more

Foodman CPAs & Advisors

IRS Relief For Certain Late-Filed International Documents

Foodman CPAs & Advisors on

On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...more

Bilzin Sumberg

FinCEN Releases Guidance Materials on the Beneficial Ownership Information for CTA Reporting

Bilzin Sumberg on

On March 24, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial...more

Freeman Law

Unreported Foreign Accounts? How to Choose the "Right" International Tax Attorney to Help You

Freeman Law on

If you have unreported foreign accounts, you are not alone.  Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.).  The good news:  the IRS offers...more

Holland & Knight LLP

¿Cuáles fiscos de América Latina reciben automáticamente información de USA y cómo funciona?

Holland & Knight LLP on

El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more

Stikeman Elliott LLP

Reviewing the 2022 Fall Economic Statement and Other Announcements

Stikeman Elliott LLP on

The past week was a busy one for Canada’s Department of Finance (“Finance”). On November 3, 2022, Finance released its 2022 Fall Economic Statement (the “Fall Economic Statement”) and the following day, it introduced Bill...more

Freeman Law

International Tax Withholding | Chapter 3 of the Internal Revenue Code

Freeman Law on

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Freeman Law

IRS Issues FBAR Reference Guide

Freeman Law on

The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more

Miller Nash LLP

Today in Tax: New Positions on Taxation of “Staking” Rewards; New Reporting Requirements for Foreign Tax Matters

Miller Nash LLP on

Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards - While the IRS has not specifically addressed the taxation of staking rewards, they have indicated a willingness to treat these rewards in...more

Freeman Law

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

Freeman Law on

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

Freeman Law

Challenging FBAR Penalties in Federal Court: FBAR Litigation

Freeman Law on

In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more

Miller Nash LLP

Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations

Miller Nash LLP on

FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basis, as opposed to a per-form basis. However, a taxpayer with “reasonable cause”...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Freeman Law

Failure to Report Foreign Trust Results in 35% Penalty Against the Owner/Beneficiary

Freeman Law on

The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more

Hogan Lovells

Spain: Law 11/2021 implementing ATAD and other measures against fraud

Hogan Lovells on

The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Freeman Law

A Summary of the IRS’ Streamlined Filing Compliance Procedures

Freeman Law on

The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more

Conyers

IP Companies and TROs Urged to Submit Outstanding Cayman Islands Economic Substance Filings

Conyers on

The deadline set by the Cayman Islands Department for International Tax Cooperation (“DITC”) for filings by relevant entities that carry on intellectual property business (“IP Companies”) and entities claiming tax residency...more

Morgan Lewis

German Taxation of IP Rights

Morgan Lewis on

IP rights with a nexus to Germany can create a variety of tax issues under German tax law. These include aspects of German or foreign IP rights generating “German source income,” questions of withholding tax obligations, a...more

Katten Muchin Rosenman LLP

DAC6: Adieu to EU

On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more

Hogan Lovells

Important changes to DAC6 regime in the UK: impact on bank lending transactions

Hogan Lovells on

The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK ...more

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