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6013(g) Election – Treating a Foreign Spouse as a U.S. Resident

In situations where a U.S. resident is married to a nonresident, an election can be made under IRC § 6013(g) to treat that nonresident spouse as a resident alien for…

January 26, 2016

Compliance Issues Immigration

Failure to Pay Taxes Could Mean Passport Revocation or Denial

On December 4, 2015, the Fixing America’s Surface Transportation Act (“FAST Act”) was signed into law, which granted the IRS the power to revoke passports. Under the FAST Act, the…

January 20, 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

Miami New York Real Estate

U.S. to Track Secret Buyers of Luxury Real Estate

Today the Treasury Department announced that it would begin identifying and tracking buyers of high-end properties made in all-cash purchases in an effort to crack down on money laundering through…

January 13, 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

Streamlined Procedure

Eligibility for Streamlined Foreign Offshore Procedure

The Streamlined Foreign Offshore Procedure allows an individual who has U.S. tax filing obligations but is not residing in the U.S. to come into compliance with their filing obligations for…

January 5, 2016

Court Case Foreign Wills

How New York Law Deals With Foreign Wills

Individuals with dual citizenship, U.S. persons who own foreign property, foreign persons with U.S. property, and heirs of those individuals, might wonder how New York courts treat foreign wills. This…

January 4, 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

Private Tax System for the Wealthy

For decades the wealthiest individuals have been exploiting tax loopholes to save millions of dollars. The practice has become so well known that some have dubbed it the “income defense…

December 31, 2015

Compliance Issues Switzerland

Swiss Bank Julius Baer Reaches $547M U.S. Tax Evasion Settlement

On December 30, Swiss Bank Julius Baer set aside $547 million as part of its settlement with the U.S. Department of Justice for its role in assisting clients evade United…

December 30, 2015

Depreciation Foreign Tax Preparation Forms and Filings

Foreign Property and Special U.S. Depreciation Rules

Earlier this month, the Protecting Americans from Tax Hikes (PATH) Act of 2015 was signed into law. The act extended certain tax credits and made others permanent several tax provisions…

December 30, 2015

Foreign Country Filing Considerations Foreign Tax Preparation

Issues in Cross Border Charitable Giving

Internal Revenue Code § 170 allows taxpayers a deduction for charitable contributions they make to qualifying organizations. Many taxpayers may wish to donate to foreign charitable organizations and want to…

December 29, 2015

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