Flott & Co. Suggests Improved Department of State Guidance for Relinquishment...
Flott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies...
View ArticleLetter to IRS Director of Individual International Compliance About Tax and...
DEAR MR. HORTON: The Service’s approach to tax and FBAR compliance by US citizens who are dual nationals and long-term residents of other countries needs to change. The existing compliance programs do...
View ArticleAccidental Americans and US Tax Compliance: A Discussion with the IRS
Flott & Co. recently had the opportunity to discuss our proposal for changes to the existing IRS “noisy” disclosure programs (Offshore Voluntary Disclosure Program – OVDP – and the Streamlined...
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: INTRODUCING IRS FORM...
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you...
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: RULES AND CATEGORIES...
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471....
View ArticleG-IV Visas: Exclusion from Capital Gains Tax on the Sale of Principal Residence
An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien, even though the individual may live in the US for a number of years and even have...
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE SECOND IN A...
US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided...
View ArticleUS signs Six Bilateral FATCA Agreements in December
December was a fruitful month for the US Treasury Department’s efforts to implement FATCA. The Treasury Department inked another six FATCA bilateral agreements which increases the total number of...
View ArticleG-IV Visas: Taxation on US Source Capital Gains
An individual residing in the US in G-IV visa status (“G-IV Taxpayer”) is generally taxed as a nonresident alien even though the individual may live in the US for an extended period of time....
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: THE THIRD IN A SERIES...
US persons with ownership interests in foreign corporations or who are directors or officers of foreign corporations are subject to special reporting rules. The first article of this series provided...
View ArticleFILING US TAX RETURNS AND FBAR ISN’T THE WHOLE STORY: INTRODUCING IRS FORM 5471
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you...
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: RULES AND CATEGORIES...
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471....
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: RULES AND CATEGORIES...
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471....
View ArticleShifting Profits From the U.S. to Lower-Tax Jurisdictions – Opportunities...
As we approach the end of 2013, with the House scheduled to be in session for less than three more weeks this year, it appears highly unlikely that we will see any comprehensive U.S. tax reform in...
View ArticleUS signs Bilateral FATCA Agreements
Thanksgiving was quite a feast for the US Treasury Department. On November 26, 2013, the US and Costa Rica signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA) and...
View ArticleFlott & Co. Suggests Improved Department of State Guidance for Relinquishment...
Flott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies...
View ArticleLetter to IRS Director of Individual International Compliance About Tax and...
DEAR MR. HORTON: The Service’s approach to tax and FBAR compliance by US citizens who are dual nationals and long-term residents of other countries needs to change. The existing compliance programs do...
View ArticleAccidental Americans and US Tax Compliance: A Discussion with the IRS
Flott & Co. recently had the opportunity to discuss our proposal for changes to the existing IRS “noisy” disclosure programs (Offshore Voluntary Disclosure Program – OVDP – and the Streamlined...
View ArticleFILING US TAX RETURNS AND FBAR’S ISN’T THE WHOLE STORY: INTRODUCING IRS FORM...
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you...
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