International Taxation

Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS
Listen In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions. FATCA is an attempt by the IRS to “improve reporting compliance” — translation: “widen the …
Employment Taxes And The Self-Employed Global Worker – So “Un”Happy Together – Part I (4)
Listen I. Domestic Administration of Social Security Taxation and the Scope of International Coordination – continued c. The Third Aspect: Taxation of Benefits Up to 85% of social security benefits received by United States citizens and residents are included in income and subject to taxation, depending on the level of benefits, tax filing status, and …
Employment Taxes And The Self-Employed Global Worker – So “Un”Happy Together – Part I (3)
Listen I. Domestic Administration of Social Security Taxation and the Scope of International Coordination – continued b. The Second Aspect: Benefits Eligibility In general, any individual is eligible to receive United States social security benefits at the age of sixty-two if he is considered “fully insured” and has filed the necessary paperwork. An individual is …
Employment Taxes And The Self-Employed Global Worker – So “Un”Happy Together – Part I (2)
Listen I. Domestic Administration of Social Security Taxation and the Scope of International Coordination – continued a. The First Aspect: Contributions Social security contributions are imposed as a tax via the Internal Revenue Code (Code) and collected by the Department of Treasury through the Service. Two statutes apply. With respect to employers and their employees, …
Employment Taxes And The Self-Employed Global Worker – So “Un”Happy Together – Part I (1)
Listen Domestic Administration of Social Security Taxation and the Scope of International Coordination – The United States social security program consists of benefits collected from taxes on employers, employees, and the self-employed, and distributions paid out to retired workers and their dependents and survivors. There are three aspects of the United States social security program. …
UNDERSTANDING THE SOURCE OF INTEREST RULE WITHOUT SUFFERING A MIGRAINE
Listen As a general rule, interest paid by individuals, partnerships, and trusts takes its source from their place of residence.  A natural corollary to this rule is that interest paid by individuals, partnerships, and trusts that are “residents” of the United States has U.S. source. This source rule has consequences that both borrowers and lenders …