Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action
Read more →Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found
Read more →The Treasury and the IRS have announced that they will be taking targeted action against corporations employing a technique known as a tax inversion in order to avoid taxation, and have issued a fact sheet and a Notice in that respect. What happens with an inversion, is
Read more →On June 18, 2014, the IRS announced comprehensive changes to both the Streamlined and the Offshore Voluntary Disclosure Program (“OVDP”) programs. Such changes to the Streamline Program include: Streamlined Program 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States 2.
Read more →When a U.S. Partnership is formed and has one or several foreign individual partners who do not live in the United States, the income of such partnership to the partners must be assessed as to its nature to the partners in order to determine the amount of tax withholding to
Read more →Under the current U.S. tax rules, non-U.S. earnings are generally not subject to U.S. tax until the earnings are repatriated. While the U.S. tax system generally taxes income of U.S. taxpayers wherever earned, profits earned from active overseas businesses, as opposed to passive overseas investments, are generally
Read more →On September 30, 2013, FinCEN posted on their internet site, a notice announcing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (the current FBAR form). FinCEN Form 114 supersedes TD F 90-22.1 (the FBAR form that was used in prior years) and is only available
Read more →President Barack Obama released his fiscal year 2015 budget request to Congress on Tuesday March 4, 2014 and lawmakers will promptly ignore it. But the annual ritual highlights his policy priorities for the coming year and serves as a Democratic Party manifesto as Democrats seek to draw
Read more →“The Internal Revenue Service (IRS) has spent millions of dollars getting ready for FATCA and is still not prepared for the new law that goes into effect this July,” says the Treasury Inspector General for Tax Administration. Does this shock you? FATCA (Foreign Account Tax Compliance Act)
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