International Taxation Archives - Christopher J. Byrne PLLC

Traditional Individual Retirement Accounts and the Estate Tax Situs Rules for a Non-Domiciliary.

As tax season heats up it is important remember that there are certain things that can still be done to impact the 2020 tax return. An important example of this…

March 8, 2021

Entity Classification Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance

New Form 5472 Reporting Requirements

Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business is often an overlooked form. In general, this form…

December 22, 2016

Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance

Forms 5471 and 5472 – Meaning of Substantially Complete

The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners and give insight…

October 27, 2016

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…

October 27, 2016

Compliance Issues Court Case Internal Revenue Service International Taxation Tax Compliance

First FATCA Conviction

On May 9, 2016, the Justice Department announced it first FATCA related conviction. The case itself was the first time that the U.S. government had brought criminal charges based upon…

October 27, 2016

Compliance Issues Forms and Filings Internal Revenue Service International Taxation Tax Compliance

Rent-Free Living – Gift Tax Implications

Form 3520 Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts is an information return which must be filed by individuals to report certain transactions with…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty

Foreign Earned Income Exclusion or Foreign Tax Credit

It is important to understand the differences between Form 1116 Foreign Tax Credit and Form 2555 Foreign Earned Income as depending on your particular facts and circumstances one could yield…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty Tax Compliance

Taxation of Consulate Workers in the United States

Resident aliens working for foreign consulates located within the United States may wonder how much, if any, of their income is subject to U.S. taxation. The first place to look…

October 21, 2016

Business Internal Revenue Code Internal Revenue Service International Taxation Nonresidents

Nonresidents and Taxation of Online Personal Services

While taxpayers who run online businesses from the United States are generally subject to income tax and state sales tax (depending on the nature of the business, the primary location…

October 21, 2016

Internal Revenue Code Internal Revenue Service International Taxation Nonresidents U.S. Withholding

Special U.S. Tax Rates for Foreign Investors

As part of the 2013 budget negotiations between Congress and the White House over how to close the nation’s deficit, the top tax rate imposed on long term capital gains…

October 21, 2016

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,…

October 21, 2016

Blocked Income Compliance Issues Elections Foreign Tax Preparation Forms and Filings International Taxation Tax Compliance

Blocked Income: Filing Form 3115

When a foreign country places restrictions on its currency, making it difficult or impossible to readily convert into U.S. dollars, the income that has been locked up in the foreign…

October 21, 2016

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