Under the Foreign Account Tax Compliance Act (FATCA), foreign banks, insurers and investment funds must send the Internal Revenue Service information about Americans' and U.S. permanent residents' offshore accounts worth more than $50,000. Institutions that fail to comply could effectively be frozen out of U.S. markets. "Since the 2012 release of the Model 1 and…
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IRS to Amend Rules for So that a US Person is Not Deamed to Own PFIC Stock Held By Their Tax Exempt Entity!
In Notice 2014-28, 2014-18 IRB, IRS has announced that it will amend the regs under Code Sec. 1291 to provide that a U.S. person that owns stock of a passive foreign investment company (PFIC) through a tax-exempt organization or account will not be treated as a shareholder of the PFIC. Code Sec. 1291 imposes a…
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IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
The Internal Revenue Service reminds U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a U.S. tax liability and a filing requirement in 2014. The filing deadline is Monday, June 16, 2014, for U.S. citizens and resident aliens…
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Offshore Prosecutions Strikes Fear into US Taxpayers
Catalogue of offshore prosecutions strikes fear into US taxpayers The US Justice Department (USDoJ) has in the past five years publicly charged 74 accountholders with offshore banking offences, of whom 61 have pleaded guilty, seven were convicted at trial and five await trial. Of the 38 bankers and advisors charged, six have pleaded guilty and…
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