IRS Deputy Associate Chief Counsel (International) Ronald Dabrowski said FATCA guidance is a key priority. The law requires foreign banks to disclose U.S. owned accounts to U.S. tax authorities or face, in some cases, a 30 percent withholding tax. Speaking at the fall meeting of the American Bar Association Section of Taxation, Dabrowski said IRS is…
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The New Gift Tax Audits – IRS Identifies Non-Filers Using State Property Records
A new IRS gift tax compliance initiative responds to suspicions of widespread failure to file gift tax returns. According to Josephine Bonaffini, the Federal/State Coordinator for the IRS Estate and Gift Tax Program, between sixty percent and ninety percent of taxpayers fail to file a gift tax return despite having engaged in a transaction requiring…
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Achieving Tax Efficiency with cross-border services and royalties in Latin America
In the global economy the growth of royalties and services associated to intellectual property and information technology has become critical for international taxation. On one-side governments of importing countries regularly source payments as territorial, based on the jurisdiction or location of payor. On the other, exporting countries push to resolve the issue through tax treaties.…
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Foreign Investors in U.S. Partnerships Miss Schedule P
Foreign investors often miss Schedule P. It applies to the ownership of any U.S. partnership including a limited liability company. Many foreign investors use a foreign corporation with the hope of avoiding US estate taxes. Now, the 2011 Schedule P (Form 1120-F) is required by a foreign corporation’s ownership of a U.S. partnership. Schedule P…
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