International Taxation Archives - Page 2 of 3

U.S. Beneficiary of Foreign Grantor Trust and Non Grantor Trust

A U.S. beneficiary of both a Foreign Grantor Trust and Non-Grantor Trust has certain reporting obligations that they must meet with respect to their interest in a foreign trust. Form…

October 21, 2016

Compliance Issues FATCA Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance

Bahamas Leak

Just months after the massive document leak known as the Panama Papers, 1.3 million files from the Bahama’s corporate registry has hit the internet in what is being referred to…

October 19, 2016

Foreign Tax Preparation International Taxation International Treaty Tax Compliance

Application of Tax Treaties to U.S. Citizens Residing Abroad

U.S. citizens and residents earning income abroad may find that their income is subject to tax in multiple jurisdictions. Some of the effects of double taxation on foreign source wages,…

August 18, 2016

Internal Revenue Code International Taxation International Treaty Tax Compliance

Stock Redemptions for Nonresident Aliens

The IRS treats a stock redemption as either a dividend or a capital gain. According to Internal Revenue Code § 302, if a stockholder’s equity interest remains relatively the same…

July 5, 2016

Forms and Filings International Taxation Visas

Tax Consequences of the EB-5 Program

In 1990, Congress created the EB-5 program to stimulate the U.S. economy through job creation and capital investment by foreign investors. The EB-5 program grants green cards to immigrants who…

June 22, 2016

International Taxation OVDI Tax Amnesty

Tax Evaders Come Clean in Germany

In 2014, Uli Hoeness, a celebrity soccer manager in Germany, was sentenced to three and a half years in prison for evading € 28.3 million in taxes. The case was…

February 8, 2016

Argentina Blocked Income Controlled Foreign Corporation ("CFC") Foreign Tax Preparation Forms and Filings International Taxation Subpart F Income

Tax Consequences of Blocked Income in Foreign Countries

Some countries put restrictions on currency, effectively ‘blocking the income’ from being readily convertible into other currencies, including U.S. dollars. Such currency control was recently in place in Argentina, where…

January 14, 2016

Compliance Issues Foreign Tax Preparation International Taxation

Tax Consequences of Foreign Currency Fluctuations

In 2015, the Brazilian Real declined against the U.S. dollar by more than 30%. The currency fell sharply in the first trading session of the year, sinking as low as…

January 11, 2016

Foreign Tax Preparation International Taxation International Treaty

Hidden Traps in the Foreign Tax Credit

The Foreign Tax credit is important to keep in mind for any individual who pays or accrues foreign tax on foreign income which is also subject to U.S. tax. Not…

December 31, 2015

Compliance Issues FDAP International Taxation Portfolio Interest and Debt

Estate Planning Amid Rising Interest Rates

For the first time since the financial crisis, the Federal Reserve has taken the first step in raising interest rates. Changing interest rates can seriously affect estate plans of affluent…

December 28, 2015

Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation International Treaty United Kingdom

Alimony payments to nonresidents under the UK- U.S. tax treaty

Generally alimony paid by a U.S. citizen or resident of the U.S. to a non-resident Alien is U.S.-source income, deductible by the payor and reportable by the recipient. Because alimony…

September 11, 2014

Compliance Issues International Taxation

FATCA Timeline and Overview

FATCA, or the Foreign Tax Compliance Act, say international tax attorneys, is a new U.S law that will have a significant effect on the reporting of financial information and tax…

July 15, 2013

Category: International Taxation