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US Tax Compliance and Planning – The Offshore Voluntary Disclosure Program...

By: Joseph Siegmann, Christopher Klug, and Sakinah Tillman The Internal Revenue Service (IRS) created the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Domestic Offshore Procedure...

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors...

The article was first published in Global Tax Weekly, issue 163. Below is the full text of the fifth article in the series on US taxes for US persons living outside the US. US Tax Compliance And...

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The US Foreign Account Tax Compliance Act

The article was first published in Global Tax Weekly, issue 167. Below is the full text of the sixth article in the series on US taxes for US persons living outside the US.  The US Foreign Account Tax...

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors...

The article was first published in  Global Tax Weekly, issue 170. Below is the full text of the seventh article in the series on US taxes for US persons living outside the US. US Tax Compliance And...

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US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors...

The article was first published in Global Tax Weekly, issue 174. Below is the full text of the eighth article in the series on US taxes for US persons living outside the US. by Stephen Flott,...

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IRS Proposes Changes to Reporting Requirements for Foreign Owned US...

Internal Revenue Bulletin 2016-21, issued May 23, 2016, by the Internal Revenue Service (IRS) and Treasury Department included a notice of proposed rulemaking altering the reporting requirements for US...

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New Disclosure Requirements for US LLCs and other Business Entities owned by...

On 13 December 2016, the Department of Treasury and Internal Revenue Service (“IRS”) issued final regulations creating reporting and record keeping requirements for US disregarded entities owned by...

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IRS Reminder – Offshore Voluntary Compliance Program (OVDP) Ends September...

The IRS recently released a reminder that taxpayers have until September 28, 2018 to apply for the OVDP. While the Streamlined Filing Offshore Procedure (SFOP), Streamline Domestic Offshore Procedures...

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Banker Pleaded Guilty to Violating the Foreign Account Tax Compliance Act...

The Department of Justice (DOJ) announced that banker Adrian Baron of Loyal Bank Ltd. pleaded guilty to “conspiring to defraud the United States by failing to comply with the Foreign Account Tax...

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Is Income from Passive Foreign Investment Corporations Gross Income?

The Tax Court’s decision in Toso v. Commissioner, was a mixed bag for taxpayers as it relates to Passive Foreign Investment Corporations (PFICs).  The taxpayer argued that for purposes of extending the...

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