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FATCA update – Ongoing Negotiations (50 countries) that are closing the global net

As we noted in our blog IRS Moves FATCA Timelines, the IRS has pushed back the dates for implementation of various provisions of FATCA – but the Treasury Department is not sitting still. On November 8th the Treasury announced: “… that it is engaged with more than 50 countries and jurisdictions around the world to […]

Is your Swiss bank account UK tax compliant?

Following the signing of the UK-Swiss tax agreement in October this year, Swiss banks are currently writing letters to all account holders who have a connection with the UK.  Letters are also being sent to those considered to be “relevant persons” in respect of trusts and foundations that hold Swiss accounts (settlors and beneficiaries would […]

Defense of Marriage Act Unconstitutional in Second Circuit Court

In our June Blog we discussed a federal district court case (southern district of New York) that had ruled that a portion of the Defense of Marriage Act (DOMA) was unconstitutional. As we noted, however, the case had limited precedential authority as it was just a lower level federal court.  The case was appealed to […]

You can’t necessarily plead the Fifth this time

As should be clear to anyone reading our blog —- if you are not up to date with your US tax filings THE IRS IS COMING TO GET YOU! More and more non-US advisors, banks, and trust companies, for example, are requiring their US clients to be complaint with their US tax obligations; some are […]

What is a US Person for IRS tax purposes?

Please note a newer post was published on this topic in March 2020. What is the IRS definition of a US Person? The below discussion focuses on individuals, however, entities, such as corporations, partnerships, and trusts are also US persons and have worldwide tax and reporting obligations as well, including the FBAR or Fincen form […]

Renounce US citizenship (Expatriation)

The United States imposes its Income Tax on US PERSONS based on the person’s worldwide income.  It does not matter where you live – if you are a US PERSON or as an advisor have a US PERSON in your investment structure, you (or they) are subject to US Income Tax. Many American citizens who […]

IRS Tax Benefits Increases for 2013

The IRS has recently announced various tax benefits increases for 2013 which will be of interest to our clients: WASHINGTON — For tax year 2013, the Internal Revenue Service announced today annual inflation adjustments for more than two dozen tax provisions. The annual exclusion for gifts rises to $14,000 for 2013, up from $13,000 for […]

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