FOREIGN ACCOUNT TAX COMPLIANCE ACT – FATCA

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The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, is an important development in U.S efforts to combat tax evasion by U.S persons holding accounts and other financial assets offshore.  FATCA requires specified U.S. tax payers to disclose their foreign financial assets to the IRS on Form 8938, Statement of Specified Foreign Financial Assets.…

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MECHANISMS FOR RELIEF OF DOUBLE TAXATION

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Double taxation is defined as the levying of tax by two or more jurisdictions on the same declared income, asset, or financial transaction. Double taxation can occur when income is taxed both at the corporate level and at the individual level. Another time when we can see double taxation is when the same income is…

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US TAXATION OF NONRESIDENTS

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The United States has one of the most complex tax law regimes in the world. A regime which nonresidents should try to avoid, if possible. Recent tax law changes have only increased the reporting requirements for United States citizens and residents, and nonresidents could be subject to the same rules, depending on their visa status,…

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GLOBAL INTANGIBLE LOW-TAXED INCOME INCLUSION (“GILTI”)

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The Tax Cuts and Jobs Act of 2017 (“TCJA”) brought forth a sea of changes in tax law and one of the most consequential of these changes is the new rules under Code Sec. 951A, Global Intangible Low-Taxed Income Inclusion (“GILTI”).  Moving to a territorial tax system for corporations, as the world has been using…

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PASSIVE FOREIGN INVESTMENT COMPANIES (“PFICS”)

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United States citizens and tax residents are discouraged from investing in Passive Foreign Investment Companies (PFICs) with primarily passive income and assets. Since 1986, the United States government has enacted a punitive regime against U.S investors investing in PFICs and one in which such investors would be subject to tax at the highest applicable marginal…

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LAST MINUTE TAX EXTENDERS

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Many of the tax provisions below were set to expire at the end of 2017 but have now been extended through 2020. You may consider amending your 2018 for a refund if any of the provisions below applies to you. The above-the-line qualified tuition and related expenses deduction is back and has been extended through 2020.  When…

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TOP 10 THINGS EXPATS RESIDING OUTSIDE THE U.S. NEED TO KNOW

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1. Expats still have to file in the US           The US tax system is based on citizenship rather than residency.  Wherever you make your home as an expat, you are required to file a U.S. tax return and report your worldwide income. 2. Expats get an automatic filing extension   The IRS provides expats an extra two months to…

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