FATCA Enforcement Softens

Realizing the large administrative burden of FATCA, the IRS has announced a “soft opening” of FATCA and enforcement at the IRS’ discretion for an initial transitional period.  FATCA, which was signed in March 2010, requires foreign

Tax treaty tie-breakers

Under many US tax treaties, if a foreign individual is a tax resident of both the US and his home country then certain ‘tie breaker’ rules will apply to determine tax residence for treaty purposes.