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Zurich Life Insurance Company Hit with Penalties for Unit-Linked Life Insurance Policies

From DOJ press release, excerpts below: Zurich Life Insurance Company Ltd (Zurich Life), headquartered in Zurich, Switzerland, and Zurich International Life Limited (Zurich International Life), headquartered in the Isle of Man (collectively Zurich) reached a resolution with the United States Department of Justice…As part of the agreement, Zurich will pay a penalty of $5,115,000 to … Read more

U.S. Tax Treatment of U.K. Pension Plans

Contents1 U.S. Tax Treatment of U.K. Retirement & Pension Plans1.1 Types of U.K. Pensions1.2 Step 1: Defined benefit vs. defined contribution foreign pensions1.3 Step 2: Employees’ trust vs. grantor trust1.4 Step 3: Broad-based & non-discriminatory1.5 U.S.-U.K. Tax Treaty U.S. Tax Treatment of U.K. Retirement & Pension Plans Few things are more confusing for U.K. foreign … Read more

IRS Wins Default Judgment in $18M FBAR Penalty Case

Contents1 IRS Wins Default Judgment in $18M FBAR Penalty Case2 Summary of the FBAR suit3 What is an FBAR penalty suit?4 Maximum FBAR penalty amount5 FBAR penalty statute of limitations on assessment6 FBAR penalty statute of limitations on collection7 Challenging FBAR penalties — pre-assessment vs. post assessment Appeals8 What should non-compliant taxpayers do? IRS Wins … Read more

How to Read Tax Treaties

Contents1 How to Read Tax Treaties – Example IRA distribution for U.S. expat in the U.K.2 Step 1: Determine residency3 Step 2: Classify the income4 Step 3: Determine if the saving clause applies5 Step 4: Determine if there is an exception to the savings clause6 Step 5: Claim either a treaty-based return position or foreign … Read more