A new exception now has been added to the list. Under final regulations issued under Section 881, the IRS can treat a disregarded entity in a financing structure as a person separate from its owner (that is, as a non-disregarded entity), in determining whether a financing arrangement exists that should be recharacterized under the multiple-party…
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Moving Accounts To Non Complying Banks -2012's Loophole?
Great article by Dick Harvey on FATCA. Will taxpayers defeat FATCA by moving their foreign accounts to foreign banks which don’t care if they can’t sell US securities? They may decide not to cough up the names and SSN’s of their “U.S. persons.” Those banks will be known as NP-FFI’s: non-participating foreign financial institutions. Offshore…
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Tax Court: State Law Protects Spouse Who Has Funds Seized From Joint Account
A Massachusetts woman whose joint bank account was seized by the Internal Revenue Service is entitled to an innocent spouse relief refund because state law says she owns half of the funds in the account, the U.S. Tax Court held Jan. 11 (Minihan v. Commissioner, T.C., No. 26595-09, 138 T.C. No. 1, 1/11/12). Writing for…
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Tax Evasion Sharpen IRS Focus on International Issues
The Internal Revenue Service is increasing its efforts to tackle international issues involving employee benefit plans as more business is done globally and as tax evasion through the use of offshore accounts grows, speakers said Jan. 11 at a benefits conference. “Experts estimate that Americans now have $1 trillion—trillion with a ‘t'—in assets offshore and…
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