FATCA Passive Foreign Investment Company

US Expatriates and PFICs

Traditionally, when a U.S. person would find themselves spending long times abroad and potentially living in a foreign country, they would start to make investments in the local economy.  Most…

Business Internal Revenue Code

Recent Changes to IRC § 1202 Small Business Stock Gains Exclusion

In December 2015, the Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) was passed by Congress and signed into law and with it made certain tax breaks permanent,…

FATCA OVDI Streamlined Procedure Tax Amnesty

More Banks Added to IRS’ Disclosure Blacklist

The IRS maintains a list of Foreign Financial Institutions or Facilitators, essentially a blacklist of institutions which have been determined to be complicit in evasion of U.S. taxes.  While taxpayers…

FATCA U.S. Withholding

FATCA: Upcoming Amendments

The Treasury and IRS are poised to amend regulations under Chapters 3 and 4 of the Internal Revenue Code regarding the Foreign Account Tax Compliance Act (“FATCA”).  These changes will…