Citizenship applications for the Caribbean island of Grenada have boomed in the last three years. Reports have emerged that Grenada’s citizenship by investment program, introduced in 2014, is being used to fast-track US E2 visa applications. Grenada is the only Caribbean country with a fast-track citizenship program, which signed a Commerce and Navigation Treaty with…Read more
All That You Wanted to Know About Form 706NA – Part I
skip to main | skip to sidebar On Tuesday, August 15, 2017 we posted Issues Concerning Filing a Form 706NA? where we discussed that deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. We also discussed that Many foreigners owning property or assets in the United…Read more
50% Owner Liable for Trust Fund Penalty Despite Not Having Primary Responsibility For Taxes.
A district court has determined on summary judgment that a 50% owner of a member-managed company, who was required to sign off on all significant decisions and actions relating to the company, was liable for the trust fund recovery penalty under Code Sec. 6672. The court found that his role in the company established that…Read more
Ireland Disagrees with EU's Decission That it Needs To Collect €13 Billion in Tax From Apple
On October 18, 2013 we posted Ireland to Close Highly Criticized Loophole, but Create an Even Bigger One where we discussed that Ireland said it planned to shut down a much-criticized tax arrangement used by Apple Inc to shelter over $40 billion from taxation, but will leave open an even bigger loophole that means the computer giant is…Read more