This Saturday, October 15th, marks the extended deadline to file your annual Report of Foreign Bank and Financial Accounts (FBAR)! If you have a financial interest or authority over any financial account located outside of the United States, and at any time during...
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International Tax Law
IRS Forms K-2 and K-3 Could Be For You
It isn’t too late to get it right in filing your 2021 tax return if you are a partnership, S corporation, or stakeholder in a foreign partnership, by reporting items of “international tax relevance” on IRS Forms K-2 and K-3. This can even include the requirement to...
Malta Pension Funds Deemed Taxable in the U.S.
Receive a pension distribution from a Malta pension fund? If you are a U.S. citizen, you will be unhappy to learn that the distribution is taxable for U.S. purposes, following the discovery of abuse by U.S. taxpayers with no prior connection to Malta. Through a...
South Dakota – the New Switzerland for Bank Secrecy?
Switzerland, Singapore, and South Dakota all have something in common…these jurisdictions are favored by the extremely wealthy for bank secrecy, which often includes tax evasion, money laundering, and other crimes including worker exploitation. In 2014, Trident Trust...
Joint Chiefs of Global Tax Enforcement Report on Progress Identifying Massive Global Tax Cheats
It has been two years since international tax leaders from Australia, Canada, the Netherlands, the United Kingdom, and the United States joined forces in the “J5” to combine resources to target enablers of tax crime, particularly related to virtual currency. Since its...
Good News for the Cannabis Industry?
As recently discussed here, the current state of the law allows business owners in the cannabis industry to take certain deductions on their state income tax returns, but not on their federal tax returns. That may soon change. The House Judiciary Committee approved...
Bilateral India-US Advance Pricing Agreement Requests Open Feb. 16
The US Internal Revenue Service announced that their Advance Pricing and Mutual Agreement office will begin accepting requests for bilateral advance pricing agrements between the United States and India starting February 16, 2016. These agreements will help make...
Six More Banks Reach Resolutions with the Department of Justices’ Swiss Bank Program
During the last two weeks of 2015, the United States Department of Justice announced that Bank Lombard Odier& Co Ltd, DZ Privatbank (Schweiz) AG, Bank J. Safra Sarasin AG, Coutts & Co Ltd, Gonet & Cie, and Banque Cantonal du Valais reached resolutions...
The IRS Urges Taxpayers to Strongly Consider Offshore Compliance
Now that the United States and numerous foreign jurisdictions have begun the automatic third-party financial account reporting exchange, it is less likely that offshore financial accounts will go unnoticed by the IRS. The IRS reminds taxpayers to take advantage...
IRS Begins Reciprocal Information Sharing with Foreign Governments – the Risks of Hiding Money Offshore is Increasing
The IRS met its deadline to begin the reciprocal automatic exchange of tax information with some foreign jurisdiction tax administrators as agreed under the intergovernmental agreements (IGAs) as part of the Foreign Account Tax Compliance Act (FATCA). As of September...
