The Tax Issues of Expatriation
...not more than 10 years during the 15-year tax period ending with the tax year during which the expatriation occurs. For the purpose of determining U.S. residency, use the substantial...
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IRS expands use of Subpeonas
...gateway into the U.S. banking system for offshore banks by maintaining correspondent bank accounts for them. By granting the summonses for correspondent banking accounts, federal courts effectively extended the reach...
Beware: India to sign FATCA agreement with US for sharing of information
...has not renounced U.S. citizenship); A lawful resident of the U.S. (including any U.S. green card holder); Most U.S. visa holders (including H-1 and L-1 visa holders); A person residing...
Another Swiss Bank Discloses Customer Names to the US
...give up the banking secrecy so embedded in Swiss culture and the world’s largest offshore financial center. BSI acknowledged that it issued pre-paid debit cards to U.S. clients without their...
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
...that it’s a bad bet to hide money and income offshore,” said IRS Commissioner John Koskinen. “Taxpayers are best served by coming in voluntarily and getting their taxes and filing...
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
...instructions or advice received regarding holding or receiving mail from the bank, etc. Further questions often lay within the responses to each of the foregoing questions. Best said if taxpayers...
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
...taxpayers who made submissions under the 2012 Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers: The risk assessment process associated with the 2012 Streamlined Filing Compliance Procedures for Non-Resident,...
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
...taxpayers. There is a provision for third party reporting under FATCA for FFIs which states, “Foreign financial institutions may provide to the IRS, third-party information reporting about financial accounts, including...
IRS’ first-time penalty abatement administrative waiver (FTA)
...this month the IRS further revised the FTA process by further requiring taxpayers to be current with current year filing and tax payments. Despite the advantages of this IRS waiver,...
Canada and US sign FATCA tax deal where banks to share information with IRS
Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S....
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
...required by FATCA about consenting U.S. accounts directly to the IRS. This requirement is supplemented by government-to-government exchange of information regarding certain pre-existing non-consenting accounts on request. Malta, the Netherlands,...
Pre-immigration estate planning
...for US gift and estate tax purposes. Pre-immigration estate tax planning in this context means pre-domiciliary estate planning. Because of the limited scope of the US gift tax in the...