Archive | February, 2013

UBS Ordered to Provide IRS with Information on other Swiss Banks

February 27, 2013  |   Posted by :   |   Unreported Income   |   0 Comments

By Michael Cohn, Accounting Today 1/29/13 “On 1/29/13, Judge Pauley (Federal Judge, U.S. District Judge William H. Pauley III) directed the IRS to issue a summons requiring the Swiss Bank, UBS, to produce information about U.S. taxpayers who were trying to evade U.S. income taxes by holding accounts at other Swiss banks that did business […]

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Non-Qualified Intermediary – NQI

February 27, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

Payors of U.S. source income to a NQI can treat the payment as reasonably associated with valid documentation from a specific payee, if prior to making the payment; 1. The payor can allocate the payment to a valid Form W8 IMY; 2. The payor can determine how much of the payment relates to valid documentation […]

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Qualified Intermediary – QI General

February 26, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

A QI is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified withholding agreement with the IRS. A QI is a payee (of U.S. source income) to the extent the QI assumes primary withholding responsibility as primary Form 1099 reporting and backup withholding responsibility for a payment, in […]

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Qualified Intermediary – Withholding Rules

February 26, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

A qualified intermediary (“QI”) is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified withholding agreement with the IRS: 1. For NRA tax withholding, unlike payments to foreign intermediaries, where the payees are the persons to whom the foreign intermediary collects the payments (e.g. account holders), the QI […]

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FATCA Update – Overseas Accounts

February 25, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

On 1/17/13, the U.S. Treasury Department published new U.S. information- reporting rules on overseas accounts to catch Americans who dodge U.S. taxes by secreting their assets offshore. Targeting foreign banks, the Foreign Account Tax Compliance Act (“FATCA”) rules, published 1/17/13 by the U.S. Treasury, require foreign financial institutions with $50,000 of any American taxpayer’s assets […]

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2013 Tax – Income Tax

February 21, 2013  |   Posted by :   |   Income Tax   |   0 Comments

In 2012, the highest income tax rate (U.S./California blended tax rate) was 42.99%: Federal tax rate: 35%; California tax rate: 12.3%. In 2013, the highest income tax rate is 51.7% (Federal tax rate: 44.3%, California tax rate: 13.3%; the 51.7% tax rate applies to wage earners). For investors the top rate on net investment income […]

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Musicians – U.S. Tax International Income

February 13, 2013  |   Posted by :   |   International Tax Planning   |   0 Comments

In 2013, the music industry is poised for a comeback, “…annual music sales in the U.S. to hover at $5.5billion over the next 3 years as declining physical sales are replaced by digital… that’s a relief for an industry that was in free fall for the past decade.” (see: Bloomberg Business Week, Feb 7, 2013, […]

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Foreign Persons – U.S. Tax Withholding – Nonresident Aliens

February 07, 2013  |   Posted by :   |   International Tax Planning   |   0 Comments

Withholding Agents: Withholding Agents are third parties required to withhold income tax on U.S. source income they pay to: 1. Foreign persons (including non-resident aliens); 2. Foreign corporations; 3. Foreign partnerships; 4. Foreign trusts; 5. Foreign estates; 6. Foreign governments; and 7. International organizations. Withholding agents are responsible for: 1. Withholding on various types of […]

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