Our Blog - Page 3 of 9 - Christopher J. Byrne PLLC

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

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

Entity Classification Internal Revenue Code Internal Revenue Service

Changes to the § 108 Exclusion Rule

Normally, under Internal Revenue Code § 61(a)(12), income from the discharge of indebtedness is includable in gross income, however, such income may be excludable from gross income under certain exceptions…

October 19, 2016

Business Compliance Issues Tax Compliance

Incorporation Transparency and Law Enforcement Assistance Act

Earlier this year, Representatives Carolyn B. Maloney and Peter King, both New York Congressmen, reintroduced legislation in the House of Representatives that would require disclosure of a corporation’s beneficial owner;…

October 19, 2016

Court Case FATCA Israel

Israeli High Court Dismisses FATCA Petition

A local branch of the U.S. Republican Party had filed a petition on January 11, 2016 with the High Court of Justice in Israel, Israel’s highest court, opposing FATCA laws. …

September 22, 2016

Log In

Forgotten Password