International Taxation

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 …
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 …
Lessons Learned from Manafort Conviction that Every Taxpayer Should Know
Listen The conviction of former Trump campaign chairman Paul Manafort on eight counts of financial crimes marks the first trial victory of Special Counsel Robert Mueller’s probing investigation into President Trump’s associates. After four days of deliberating, the jury found Manafort guilty of five counts of filing false tax returns on tens of millions of …