Discussion of matters broadly related to international taxation and cross-border income and assets.
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…
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…
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…
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…
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,…
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…
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…
