U.S. demands UBS “comply in full” in tax evasion case
By Tom Brown, Reuters.com The U.S. Justice Department said on Tuesday it was pressing ahead with its five-month-old lawsuit against UBS AG to force the Swiss bank to identify thousands of U.S. clients...
View ArticleIRS Releases Streamlined Offshore Voluntary Disclosure Form
From JournalofAccountancy.com The IRS has posted to its Web site a three-page “optional format” short form for taxpayers to use when applying for the Voluntary Disclosure Program. The form asks...
View ArticleMedicare Tax on Investment Income
On March 25, 2010, Congress passed the Healthcare and Education Reconciliation Act of 2010 (H.R. 4872). The Reconciliation Act amends various provisions of the Patient Protection and Affordable Care...
View ArticleH.I.R.E. and the Foreign Account Tax Compliance Act
On Thursday, March 18, 2010 President Obama signed the Hiring Incentives to Restore Employment Act (H.R. 2847). Included in the bills’ provisions is the Foreign Account Tax Compliance Act. This Act...
View ArticleTax Provisions and the Health Reconciliation Act
On March 25, 2010, Congress passed the Healthcare and Education Reconciliation Act of 2010 (H.R. 4872). Included in this tax act is the Economic Substance Doctrine (new IRC Section 7701(o)). The test...
View ArticleSummary of HIRE and Foreign Account Tax Compliance Act
On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment (“HIRE”) Act (P.L. 111-147) (The “Act”) which included the Foreign Account Tax Compliance Act containing new...
View ArticleForeign Account Tax Compliance – Withholding Agents
The Foreign Account Tax Compliance Act (The “Act”) expands withholding rules and additional reporting requirements for foreign financial institutions and non-financial foreign entities. Under U.S. tax...
View ArticleForeign Account Tax Compliance Act: Foreign Financial Assets
U.S. Taxpayers who hold any interests in specified foreign financial assets during the tax year must attach their tax returns for the year certain information with respect to each asset if the...
View ArticleU.S. Tax Compliance – Foreign Grantor Trusts – Foreign Gifts
If a Foreign Trust has a U.S. grantor, and one or more U.S. beneficiaries, under IRC §679 the Trust is classified as a foreign grantor trust and all Trust income, deductions and credits must be...
View ArticleForeign Grantor Trusts – 2010 HIRE Act
The 1996 Small Business Job Protection Act (“1996 Act”) established new reporting requirements for Foreign Gifts and Foreign Grantor Trusts. The 2010 HIRE Act included the Foreign Account Tax...
View Article
