Forms and Filings Archives - Page 2 of 3 - Christopher J. Byrne PLLC

U.S. Beneficiary of Foreign Grantor Trust and Non Grantor Trust

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…

October 21, 2016

Business Compliance Issues Elections Entity Classification Forms and Filings Internal Revenue Code

Proposed Regulations regarding Foreign-Owned Domestic LLCs

Under current regulations, spanning from Treas. Reg. §§ 301.7701-1 through 301.7701-3, a domestic limited liability company (“LLC”) organized under the laws of the United States, with only one member is…

July 6, 2016

Compliance Issues FATCA Forms and Filings Internal Revenue Code International Treaty U.S. Withholding

Changes to Form W-8BEN-E

Form W-8BEN-E Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities) is a form prepared by a foreign entity which must be provided to a…

July 6, 2016

Forms and Filings International Taxation Visas

Tax Consequences of the EB-5 Program

In 1990, Congress created the EB-5 program to stimulate the U.S. economy through job creation and capital investment by foreign investors. The EB-5 program grants green cards to immigrants who…

June 22, 2016

Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance

Form 3520 – Substituting the Foreign Grantor Trust Beneficiary Statement

Beneficiaries of Foreign Grantor Trusts will generally receive a Foreign Grantor Trust Beneficiary Statement detailing information for the tax year related to that trust. Question 29 of Part III of…

June 22, 2016

Compliance Issues Forms and Filings Tax Compliance U.S. Withholding

FIRPTA Changes Encourage New Wave of Foreign Investment

Congress amended the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”) in the Protecting Americans from Tax Hikes Act of 2015, signed into law on December 18, 2015. …

June 16, 2016

Compliance Issues FBAR Forms and Filings

Proposed Rules for Bank Secrecy Act Regulations

On March 1st, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rules to modify regulations issued under the 2011 Bank Secrecy Act regarding the reporting…

June 16, 2016

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…

January 26, 2016

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…

January 14, 2016

Depreciation Foreign Tax Preparation Forms and Filings

Foreign Property and Special U.S. Depreciation Rules

Earlier this month, the Protecting Americans from Tax Hikes (PATH) Act of 2015 was signed into law. The act extended certain tax credits and made others permanent several tax provisions…

December 30, 2015

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…

August 24, 2015

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…

September 11, 2014

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