CFCs and Subpart F Income
While a U.S. corporation is subject to tax on its earnings and then its shareholders on their dividends, the U.S. has no taxing jurisdiction on …
While a U.S. corporation is subject to tax on its earnings and then its shareholders on their dividends, the U.S. has no taxing jurisdiction on …
FATCA, treaty exchanges, and deferred prosecution agreements are some of the ways that IRS can be tipped off to your foreign accounts. Foreign Account Tax …
FIRPTA witholding rules may apply to a disposition of a U.S. real property interest by a foreign person. Such transactions are subject to the Foreign …
A question that’s commonly asked by prospective clients in a streamlined compliance filing is: “will I get audited?” This article will hopefully shed some light. …
How U.S. Life Insurance Policies are Taxed A whole life insurance policy is part investment and part life insurance. Such policies have two basic financial …
How much does a streamlined case cost? Foreign accounts cases are unique and present different challenges. We often get quote requests by email. Hopefully this …
Domestic Voluntary Disclosure The IRS issued a memorandum on November 29, 2018 that updates the process for domestic and offshore voluntary disclosures after the 2014 offshore voluntary disclosure program …
When a U.S. person receives a gift from a foreign person in excess of $100,000, the transaction triggers a Form 3520 filing requirement. There are …
Texas is a community property state, which means that all “community property” is owned jointly and equally by both spouses. In Texas, all property accumulated …
“FATCA” (Foreign Account Tax Compliance Act) requires specified individuals to report ownership of specified foreign financial assets if the total value exceeds the applicable reporting …