Foreign Tax Preparation 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

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

Foreign Tax Preparation International Treaty Tax Compliance

Foreign Tax Credit – Federal and North Carolina

When filing a federal tax return, a taxpayer may qualify for the foreign tax credit. The foreign tax credit may be claimed for foreign tax imposed on a taxpayer by…

July 5, 2016

Business Entity Classification Foreign Tax Preparation Internal Revenue Code International Treaty

Foreign Investors in S-Corporations

Pursuant to Internal Revenue Code § 1361, there are certain restrictions to qualify for S-Corporation status; one of which is that a shareholder cannot be a nonresident alien. If a…

June 22, 2016

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

Form 3520 – Substituting the Foreign Grantor Trust Beneficiary Statement

Beneficiaries of Foreign Grantor Trusts will generally receive a Foreign Grantor Trust Beneficiary Statement detailing information for the tax year related to that trust. Question 29 of Part III of…

June 22, 2016

Foreign Tax Preparation Internal Revenue Code Internal Revenue Service Tax Compliance

Nonresident Aliens and the § 121 Principal Residence Exclusion

Internal Revenue Code § 121 provides taxpayers with an exclusion from gross income of up to $250,000 of gain on the sale of a taxpayer’s principal residence. A married couple…

June 22, 2016

Compliance Issues Foreign Tax Preparation Internal Revenue Service Tax Amnesty Tax Compliance

Justice Department and IRS Continue to Crackdown on Switzerland, Expand Investigation into Belize

The U.S. Justice Department recently projected that it would collect more than $1.36 billion from 80 Swiss banks and other Swiss financial firms that encouraged U.S. taxpayers to hide money…

March 25, 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

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

Category: Foreign Tax Preparation

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

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

Foreign Tax Credit – Federal and North Carolina

Foreign Investors in S-Corporations

Form 3520 – Substituting the Foreign Grantor Trust Beneficiary Statement

Nonresident Aliens and the § 121 Principal Residence Exclusion

Justice Department and IRS Continue to Crackdown on Switzerland, Expand Investigation into Belize

Tax Consequences of Blocked Income in Foreign Countries

Tax Consequences of Foreign Currency Fluctuations

Hidden Traps in the Foreign Tax Credit

Foreign Property and Special U.S. Depreciation Rules

Issues in Cross Border Charitable Giving

Christopher J. Byrne PLLC

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