Wealth Taxes, Estate Taxes and the Loss of the Step Up in Basis at Death.
As discussed in an earlier post, the concept of a “Wealth Tax” has resurfaced as a possibility in the U.S. again in the form of a proposal titled the “Ultra-Millionaire…
Category: Foreign Country Filing Considerations
Compliance Issues France Germany International Taxation International Treaty Switzerland Tax Compliance
UBS to Share Client Information with France
In recent years, Switzerland’s strict bank secrecy laws have made assets in the country a target of investigation for tax authorities around the world. This week, the Swiss Federal Tax…
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,…
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…
Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation International Treaty United Kingdom
Alimony payments to nonresidents under the UK- U.S. tax treaty
Generally alimony paid by a U.S. citizen or resident of the U.S. to a non-resident Alien is U.S.-source income, deductible by the payor and reportable by the recipient. Because alimony…