International Taxation

A Logical Program Made Unnecessarily Complicated: The IRS’ Approach to International Information Returns
Listen The process of adhering to tax rules and regulations in the United States is anything but easy. With so many deadlines and filing requirements, particularly for those living, working, or housing assets outside the United States, it’s almost impossible to keep track of everything required to stay compliant. The risk of penalty makes this …
An In-Depth Look at Reporting Requirements for Transfers from U.S. Taxpayers to Foreign Corporations
Listen Technology has led to large changes in the way the world works, from the general public’s obsession with social media to improved opportunities for international communication. And, as such, the world of business has been among the most affected. Communication is easier, international trade is easier, and, of course, operating branches and subsidiaries overseas …
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 …