Our Blog - Page 2 of 9 - Christopher J. Byrne PLLC

Gold Bullion Reporting – Form 8938 and Form 114 FBAR

Many taxpayers hold physical gold bullions as an investment tool but remain uncertain as to whether foreign physical gold assets are reportable for both Form 8938 Statement of Specified Foreign…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty

Foreign Earned Income Exclusion or Foreign Tax Credit

It is important to understand the differences between Form 1116 Foreign Tax Credit and Form 2555 Foreign Earned Income as depending on your particular facts and circumstances one could yield…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty Tax Compliance

Taxation of Consulate Workers in the United States

Resident aliens working for foreign consulates located within the United States may wonder how much, if any, of their income is subject to U.S. taxation. The first place to look…

October 21, 2016

Business Internal Revenue Code Internal Revenue Service International Taxation Nonresidents

Nonresidents and Taxation of Online Personal Services

While taxpayers who run online businesses from the United States are generally subject to income tax and state sales tax (depending on the nature of the business, the primary location…

October 21, 2016

Compliance Issues Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance

3520 Filing Deadline without a Return

Form 3520 Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts and Form 3520-A Annual Information Return of Foreign Trust with a U.S. Owner are…

October 21, 2016

Internal Revenue Code Internal Revenue Service International Taxation Nonresidents U.S. Withholding

Special U.S. Tax Rates for Foreign Investors

As part of the 2013 budget negotiations between Congress and the White House over how to close the nation’s deficit, the top tax rate imposed on long term capital gains…

October 21, 2016

Elections Forms and Filings Internal Revenue Code Nonresidents

Benefits of Election 83(b) for Nonresidents

An individual who receives property in exchange for the performance of services generally would report the fair market value of that property received as ordinary income, subjecting the individual imposition…

October 21, 2016

Foreign Country Filing Considerations Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation International Treaty U.S. Withholding

Alimony Payments by a U.S. Citizen to a Nonresident Alien

With an ever expanding global economy and migrating workforce, it comes as no surprise that marriage and divorce transcends borders as well, creating unique tax implications for those involved. Generally,…

October 21, 2016

Blocked Income Compliance Issues Elections Foreign Tax Preparation Forms and Filings International Taxation Tax Compliance

Blocked Income: Filing Form 3115

When a foreign country places restrictions on its currency, making it difficult or impossible to readily convert into U.S. dollars, the income that has been locked up in the foreign…

October 21, 2016

Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation Tax Compliance

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

Business Tax Compliance

Compliance Assurance Process

The Compliance Assurance Process (“CAP”) is a program where a team from the Internal Revenue Service (“IRS”) works with participating taxpayers collaboratively to identify and resolve potential tax issues before…

October 21, 2016

Compliance Issues Internal Revenue Code Switzerland Tax Compliance

Justice Department Expecting to Collect over $1.36 billion from Swiss Banks

In the beginning of 2016, the Justice Department reported that it is expecting to collect over $1.36 billion from 80 Swiss banks and financial institutions that admitted to aiding U.S….

October 19, 2016

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