In Chief Counsel Advice (CCA), IRS has determined the sourcing of credit card interest and fees received by a financial services firm from U.S. citizen and resident alien customers living outside the U.S. and from ATM fees earned by the firm in connection with customer transactions made on third-party ATMs located outside the U.S. The…
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New Reporitng for Foreign Investors in U.S. Partnerships
Foreign investors are now required to file a special form, Schedule P. It applies to the ownership of any U.S. partnership including a limited liability company. Now, the 2012 Schedule P (Form 1120-F) is required by a foreign corporation’s ownership of a U.S. partnership. Schedule P also reports the distributive shares of partnership effectively connected…
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IRS Has $1 Billion for People Who Have Not Filed a 2008 Income Tax Return
WASHINGTON — Refunds totaling more than $1 billion may be waiting for one million people who did not file a federal income tax return for 2008, the Internal Revenue Service announced today. However, to collect the money, a return for 2008 must be filed with the IRS no later than Tuesday, April 17, 2012. The…
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Tax Crimes as a ‘Predicate Offense' for Money Laundering?
The global body that sets standards for combating money laundering and terrorist financing said Thursday that governments should treat tax crimes as a red flag for other types of financial malfeasance, a sign that international cooperation against tax cheats is gaining momentum. The body, the Financial Action Task Force, said it was expanding its list…
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