Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?

- By : Parag Patel

…US$25,000 (US$50,000 for joint filers) or less, and if no MTM or QEF election has been made, the shareholder need not file an annual form 8621. The PFIC tax regime…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…of Foreign Financial Assets — This is a new tax form that is expected to be required for anyone with more than $50,000 in foreign financial assets in 2010. A…

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

- By : Parag Patel

…U.S. law, and may have failed to file an FBAR (FinCEN Form 114, previously Form TD F 90-22.1) and/or one or more international information returns (e.g., Forms 3520, 3520-A, 5471,…

Beware of Overlooked Common Overseas Tax Forms

- By : Parag Patel

…the highest value reached during the year and on the last day of the year. These thresholds range from a low of $50,000 to a high of $600,000. Other Overseas…

Watch Out for PFIC Status

- By : Parag Patel

…from PFIC reporting if PFIC holdings do not exceed $25,000 ($50,000 for married couples filing jointly). Third, if you hold a PFIC through an IRA or other certain retirement accounts,…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…(Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) by e-mailing the CIS ID number to “*LB&I OVDP Compliance” with an explanation that the case is being forwarded due to…

Common Issues for US-India Tax Reporting

- By : Parag Patel

…for those who hold $10,000 or more (in the aggregate) in a foreign financial account. You must also include things like life insurance policies, mutual funds, accounts you only have…

The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

- By : Parag Patel

…person with an interest in, or signature or other authority over, one or more foreign financial accounts whose aggregate value exceeds $10,000 at any time during a calendar year is…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

…filings. Any line marked with a # is for Official Use Only 1 IRM PROCEDURAL UPDATE DATE: 05/09/2016 NUMBER: WI-21-0516-0879 SUBJECT: BMF International Accounts Management AFFECTED IRM(s)/SUBSECTION(s): 21.8.2 CHANGE(s): IRM…

Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities

- By : Parag Patel

…Specified Foreign Financial Assets Foreign Trusts Reporting Forms Form 3520-A Annual Information Return of Foreign Trust With a U.S. Owner Form 3520 Annual Return to Report Transactions With Foreign Trusts…

More Tax Complexity: New Form 8938

- By : Parag Patel

…$50,000 Highest Aggregate Value at Any Time During the Year: $100,000 Filing Status: Married Filing Joint Aggregate Value at Year End: $100,000 Highest Aggregate Value at Any Time During the…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) for the foreign financial asset; and (4) these failures resulted from non-willful conduct. To be eligible for the streamlined…

The IRS is Hiring: Expect New Enforcement

- By : Parag Patel

…will be more audits with respect to Forms 5471 (owners of a foreign corporation), 3520/3520A (owners and beneficiaries of foreign trusts), 8621 (PFICs, including foreign mutual funds) and 8865 (owners…