11 Jun Are You a US Citizen Living Outside the US Contemplating Expatriation (or not) – File An Extension Request Today?
Seeking Clarity in the US Tax Code on behalf of US Taxpayers Everywhere...
International Tax
14 Jul Lessons Learned Preparing & Defending IRS Form 8938 – FATCA
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in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax, Tax Treaties
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...
27 Jun Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116
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in Foreign Tax Credit, Alien, Foreign Income, Foreign Investment, FTC, International Tax, Tax Credit, Tax Guidance & Preparation
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...
16 Jun Foreign Earned Income Exclusion (FEIE): Drill Down into IRS Form 2555
Living and working outside of the USA - anyone can do it - everyone should....
27 Apr Top International Tax Questions Answered
Fear NOT the US Tax Code - it is but a paper tiger. All are welcome!...
21 Oct Different Sources of Income Matter FDAP v. ECI
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in Alien, Alimony, Distributions, Expatriation, Foreign Income, Foreign Investment, International Tax, Paying Taxes
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...
05 Oct IRS Form 8833 – Treaty-Based Return Disclosure Under IRC 6114
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...
22 Sep Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement
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in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing
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...
09 Sep Procedures for Requesting Competent Authority Assistance under US Tax Treaties
U.S. competent authority assistance is not necessarily contingent upon whether you sign an agreement with the IRS Examination function contrary to the assertions of some IRS Revenue Agents. Turns out this is important information for some US Taxpayers of international origin in battle with the IRS. Yes...
24 Aug General ITIN References & Contact Information Including IRS Pub 1915 & IRS Rev Proc 2006-10
Aside from this tax blog the following are the most useful resources for researching Individual Taxpayer Identification Number (ITIN) application processing. IRS Publication 1915 General ITIN Information page Update to the Instructions for Form W-7 and ITIN Processing Time IRS Rev Proc 2006-10 IRS Form W-7 IRS Form W-7 Instructions If you...