Foreign Bank Account Reporting (FBAR) - FinCEN Form 114 FinCEN Financial Crimes Enforcement Network (FinCEN) is a bureau of the Treasury Department. Authorized under the Bank Secrecy Act, foreign bank account reporting commonly referred to as “FBAR†is electronically reported to the IRS via FinCen Form 114 separate and...
Foreign Financial Asset Reporting (FATCA) - Form 8938 was enacted March 18, 2010 and requires filing of Form 8938. The FATCA requirement does not replace or otherwise affect a taxpayer’s obligation to file an FinCEN Form 114. Basically if you are a US taxpayer holding foreign financial assets you...
Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116. With all the political rhetoric about borders and boundaries circulating these days by 'news media' outlets the fact of the matter is US Taxpayers are increasingly working and living abroad everyday. With that taxpayers and tax...
Living and working outside of the USA - anyone can do it - everyone should....
Fear NOT the US Tax Code - it is but a paper tiger. All are welcome!...
Different Sources of Income Matter FDAP v. ECI One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any regard to where the income is...
IRS Form 8833 - Treaty-Based Return Disclosure Under IRC 6114 - When MUST It Be Filed? While the light of my life was off at a family wedding in Fargo, ND this past weekend a friend flew into town unexpectedly from Minnesota with a complimentary ticket...
In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC...
As part of an IRS Examination under the Foreign Investment in Real Property Tax Act (FIRPTA) you absolutely must have a Taxpayer Identification Number (TIN) to mitigate 26 U.S. Code § 1445 - Withholding of tax on dispositions of United States real property interests If you do not...