Avoid Unintended Results from Complex New Rules for Intercorporate Debt In April 2016, the Treasury Department and the IRS issued proposed regulations under Sec. 385. If the proposed...
Continue ReadingAvoid Unintended Results from Complex New Rules for Intercorporate Debt In April 2016, the Treasury Department and the IRS issued proposed regulations under Sec. 385. If the proposed...
Continue ReadingWe see it happening more and more. U.S. companies are sending their employees into foreign (host) countries on temporary but at times lengthy business assignments. Employees are willingly...
Continue ReadingThe FBAR filing due date will be different next year. Hopefully you have already submitted your 2015 FBAR filing which is due by June 30th this year. If not, you still have a little time...
Continue ReadingSome U.S. taxpayers have used foreign accounts to hide income subject to U.S. taxes. As a result all U.S. taxpayers, and many non-U.S. financial institutions, must comply with information...
Continue ReadingMany people who receive income from passive foreign investment companies, or “PFICs,” have no idea that they hold an interest in an investment that may trigger additional filing...
Continue ReadingIf you or your business qualifies as a U.S. tax person, you might have to file tax returns and you might have to pay taxes. Or you might not. In a previous post, we focused on the 3 ways an...
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