The Tax Court’s decision in Toso v. Commissioner, was a mixed bag for taxpayers as it relates to Passive Foreign Investment Corporations (PFICs). The taxpayer argued that for purposes of extending the statute of limitations for assessment from 3 to 6 years under section 6501(e)(1)(A)(i) income taxed under section 1291 was not part of “gross…
DetailsThe Department of Justice (DOJ) announced that banker Adrian Baron of Loyal Bank Ltd. pleaded guilty to “conspiring to defraud the United States by failing to comply with the Foreign Account Tax Compliance Act (FATCA). According to court documents, Mr. Baron conspired with an undercover agent to conceal the undercover agent’s ownership of accounts opened…
DetailsThe IRS recently released a reminder that taxpayers have until September 28, 2018 to apply for the OVDP. While the Streamlined Filing Offshore Procedure (SFOP), Streamline Domestic Offshore Procedures (SDOP) and Delinquent International Information Return (DIIR) programs remain open, the OVDP is the only program to reduce penalties and avoid potential criminal sanctions for persons…
DetailsOn 13 December 2016, the Department of Treasury and Internal Revenue Service (“IRS”) issued final regulations creating reporting and record keeping requirements for US disregarded entities owned by non-US person. A disregarded entity is any entity with a single owner and is disregarded from its owner for US tax purposes. The IRS realized that US…
DetailsInternal Revenue Bulletin 2016-21, issued May 23, 2016, by the Internal Revenue Service (IRS) and Treasury Department included a notice of proposed rulemaking altering the reporting requirements for US disregarded entities owned by non-US persons or entities. A US disregarded entity is an entity with a single owner that is not treated as separate from…
DetailsThe article was first published in Global Tax Weekly, issue 174. Below is the full text of the eighth article in the series on US taxes for US persons living outside the US. by Stephen Flott, and Omar Saleh, Flott & Co. PC This is the eighth article in a series of articles on key US…
DetailsThe article was first published in Global Tax Weekly, issue 170. Below is the full text of the seventh article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US by Stephen Flott, Omar Saleh, and Louisa…
DetailsThe article was first published in Global Tax Weekly, issue 167. Below is the full text of the sixth article in the series on US taxes for US persons living outside the US. The US Foreign Account Tax Compliance Act by Stephen Flott, and Flott & Co. This is the sixth article in a series of…
DetailsThe article was first published in Global Tax Weekly, issue 163. Below is the full text of the fifth article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – FBAR by Stephen Flott, and Natalia Kosyak,…
DetailsBy: Joseph Siegmann, and The Internal Revenue Service (IRS) created the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Domestic Offshore Procedure (SDOP) to encourage taxpayers to disclose foreign accounts and income that were subject to reporting but were not previously reported to the IRS. While both the OVDP and SDOP encourage taxpayers to disclose…
Details