September 2018

A Quick Primer on Form 5471 and Some Hidden Pitfalls to Avoid
Listen Form 5471 is triggered in situations where a “U.S. Person” owns an interest in a “foreign” (non-U.S.) corporation. The specific reporting requirements for Form 5471 are found in Internal Revenue Code Sections 6038 and 6046. Broadly speaking, the purpose of Form 5471 is to identify “U.S. Persons” who: own at least 10% of a …
OVDP Sunsetting on September 28 – New Procedures On The Horizon
Listen On September 4, 2018, the Internal Revenue Service (IRS) reminded taxpayers that they have until September 28, 2018 to apply for the Offshore Voluntary Disclosure Program (OVDP). Back in March, the IRS announced that it would be discontinuing the program on September 28, 2018. This does not mean that the IRS is going to discontinue pursuing …
FATCA Back in the News
Listen That pestilent FATCA law is back in the news again. Back on July 9, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report (July TIGTA Report) highlighting the IRS’ shortcomings in enforcing FATCA. For those unfamiliar with FATCA, it stands for “Foreign Account Tax Compliance Act.” Sometimes referred to derisively by the …