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…

Compliance Issues Elections Forms and Filings Immigration

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…

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…

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…

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…

FIRTPA

Congress Approves FIRPTA Reform

Congress amended the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”) in the Omnibus bill that was passed last week. This opens the door to greater purchases by…

Compliance Issues Forms and Filings

Many IRS Return Due Dates Changed for 2015 Reporting Season (including FBAR) and Change to IRS Audit Period

The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 was signed into law on July 31, 2015.  This legislation changes the IRS return due dates going forward…

Compliance Issues Foreign Tax Preparation Switzerland

Credit Suisse Agrees To $196 Million Settlement With The SEC

Credit Suisse Group AG agreed to pay $196.5 million and admit wrongdoing to settle U.S. Securities and Exchange Commission charges that it provided cross-border brokerage and investment advisory services to…

Compliance Issues Foreign Tax Preparation

New Rules for 2013 Tax Year PFIC Filing (Form 8621)

On December 30, 2013, the IRS published a package of proposed, temporary, and final regulations relating to Passive Foreign Investment Companies (“PFICs”) and their shareholders. The most significant component of…