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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U.S. Wins Three Tax Cases Involving Big Banks, KPMG
United States prosecutors said Tuesday they had won three major cases against American clients of questionable tax shelters, including ones used by a Dallas billionaire and Wells Fargo Co. and others designed by Citibank and accounting firm KPMG LLP. The separate cases, the verdicts of which were rendered in October, represent a significant victory for…
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Final Form 8939 and Instructions Now Available
The IRS just released the final Form 8939 and Instructions. Form 8939 is required to be filed by an Executor of a 2010 decedent’s estate to make the election to opt out of the federal estate tax system and apply the modified carry-over basis rules under Internal Revenue Code (“IRC”) Section 1022. The deadline for…
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European Union Savings Directive (EUSD) – Amendment Is Coming Soon
Banks in EU must report beneficial owner information or implement 35% withholding tax on any interest payment to zero tax offshore entity effectively managed in the EUSD territory. There is a list of jurisdictions outside the scope of the EUSD and includes Barbados, Panama, Belize, Bermuda and Hong Kong and St.Lucia among others. Also the list includes places…
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