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. Contents1 Foreign Account …
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. …
Contents1 How U.S. Life Insurance Policies are Taxed2 Tax treatment of foreign life insurance policies2.1 Is it a qualifying life insurance policy?2.1.1 (1) Cash Value …
Contents1 How much does a streamlined case cost?2 How a streamlined case is handled2.1 Step 1: Initial consultations2.2 Step 2: Research2.3 Step 3: Tax preparation2.4 …
Contents1 Domestic Voluntary Disclosure2 Steps for Making a Voluntary Disclosure Under the Revised Guidelines2.1 1. Make a pre-clearance request2.2 2. Submit required voluntary disclosure documents2.3 …
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 …