Proven Strategies For Eliminating Excess Credits
There are three proven strategies for eliminating excess credits: 1. Foreign tax reduction planning, 2. Increasing the limitation, and 3. Cross-crediting. Part I of this blog will cover the first two. Part II will cover the third, Cross-crediting. A. Foreign Tax Reduction Planning For U.S. persons in excess limitation positions, foreign tax reduction planning has […]
Beyond the FBAR: Other IRS International Reporting Forms And Their Related Penalties Lying In Wait for the Taxpayer With Foreign Assets
With all of the focus on FBARs and Form 8938 these days, it’s sometimes easy to forget about the other IRS international reporting forms. Below is a discussion of all of the other IRS international reporting forms and their corresponding penalties. (1) Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain […]
U.S. Taxation of Entities, Associations, and Partnerships: What’s Your “Situs” Roger?
In the U.S. tax system, there is no characteristic of associations or entities (partnerships, corporations, and trusts) that corresponds exactly to the “nationality” or “residence” of individuals. For most organizations, however, there is a place – or at least a distinct legal environment – that establishes their existence and identity. This place, sometimes referred to […]
Understanding the Source of Income Rules – Part I
This blog is a primer on the source of interest rules. It is a four-part series. Let’s begin with some basics. The U.S. taxes U.S. persons on their worldwide income. Why are the source of interest rules important? Because sourcing can have a significant effect on the computation of a U.S. person’s foreign tax credit […]