Trust structures complexities
US settlors and US beneficiaries of non-US trust face a myriad of US income tax and reporting obligations that are not imposed on US settlors and US beneficiaries of US trust. In the first instance, both settlors and beneficiaries must report the income and gains of the trust allocated to them on their US income […]
FATCA: First criminal conviction for failure to comply
We knew it was coming, but this month we now have the first-ever conviction for failing to comply with FATCA. The US government with help from other countries in what reads like an international James Bond type movie thriller, complete with undercover agents in a sting operation, has shown that they will aggressively pursue those […]
IRS Update: Does your partnership agreement need to be revised?
Last month, the Internal Revenue Service (IRS) finalized proposed regulations on the designation and authority of a partnership representative under the centralized partnership audit procedures that went into effect for tax years after December 31, 2017. This article addresses some of the key points of the final regulations. Prior to discussing these regulations, we thought it […]
Pre-Immigration Planning – Private Placement Insurance Products
Today’s guest post is written by Grayson Dufrene, CLU, ChFC, TEP, Managing Director at Vie International for the last 10 years. Grayson has over 20 years’ experience working with international clients on their cross-border and wealth planning needs. Private Placement Life Insurance Products PPLI and PPVA are US compliant insurance products available to “qualified purchasers” […]
IRS: Pay Up or Lose Passport
The IRS recently announced they sent at least 362,000 names to the State Department to deny or revoke the US passport for those US Citizens who have not paid their taxes. The Internal Revenue Code allows the IRS to certify the tax debt of delinquent US taxpayer to the State Department. Following such notification, the State […]
US Taxpayers with Expiring ITINs Can Renew Number Now
US Taxpayers who have an Individual Taxpayer Identification Number (ITIN) should check to see if their numbers will be expiring at the end of the year. More than 2 million ITINs are set to expire at the end of 2018. If your ITIN has not been used on a US tax return at least once […]
5 Ways Uncle Sam Can Still Reach Non-Resident Aliens
So, you feel lucky that you are not an American citizen, with the tax headaches that a citizenship-based system bestows upon the not so lucky US expatriate. Not so fast. Even though you are not an American, you may not be safe from Uncle Sam’s long tax arms. Below are five instances where he could still […]