International Tax Compliance - Definition of U.S. Person
“Each year, in the United States alone, offshore tax evasion produces an estimated $100 billion in unpaid taxes that could help pay for health care, education, and more. It’s time to put an end to offshore tax dodging that robs the U.S. Treasury of needed funds.” —Statement of Senators Carl Levin (D-Mich.) Norm Coleman (R-Minn.), […]
International Tax Compliance - Foreign Corporation/Foreign Partnership
Foreign Corporation (Form 5471)/Foreign Partnership (Form 8865)
Control Rules
Any U.S. Person who controls a foreign corporation or foreign partnership during the tax year must file a Form 5471 (for a corporation) or Form 8865 (for a partnership). (IRC §6038.) These forms must be filed with the U.S. Person’s timely filed federal tax return (including extensions).
For foreign […]
International Tax Compliance - Foreign Disregarded Entity (U.S. Owner) Form 8858
Does The Taxpayer Own An Interest In A Foreign Disregarded Entity?
Special reporting rules also apply to U.S. Persons who are owners of a foreign disregarded entity.
Any U.S. Person that is treated as the owner of the assets or liabilities of a foreign disregarded entity is required to file a Form 8858 with its timely filed […]
International Tax Compliance - Foreign Gifts (U.S. Person)
U.S. Persons that receive gifts from foreign individuals or entities must also report such transfers.
Generally, a U.S. Person must report on a Form 3520 (1) any gifts from a non-resident individual or foreign estate that collectively exceed $ 100,000, (2) any gifts from foreign corporations and foreign partnerships that collectively exceed $10,000 (adjusted for inflation). […]
International Tax Compliance - Foreign Trust (U.S. Tax Reporting)
1. Form 3520 is filed upon initial Trust formation (within ninety (90) days of formation).Annually, this form is used to report transactions with foreign Trusts and to report receipts of foreign gifts.The Form 3520 return is due on the 15th day of the third month after the end of the year of the Trust. For […]
International Tax Compliance - Foreign Trust (U.S. Person): Reportable Event
A reportable event is generally defined as the creation or funding (with money or property) of a foreign trust by a U.S. Person, including transfers by death. It also includes the death of a U.S Person if the person was an owner of the foreign trust or any portion of the trust is includible in […]
International Tax Compliance - Foreign Bank Accounts
The FBAR rules are established in the 1970 Bank Secrecy Act (since 2003 the IRS enforces these rules).
U.S. Donor: FBAR form
The FBAR filing requirement applies if a U.S. person has a signatory power over or financial interest in a foreign bank account or securities account if the aggregate value of the accounts exceeds $10,000.
The U.S. […]
International Tax Compliance - IRS Tax Audit Strategy
Private placement life insurance is a pre-emptive IRS audit tax strategy that transforms taxable ordinary income and capital gains into tax-free income (with no income tax reporting required under current U.S. Law). Please reference IRS Private Letter Ruling 200244001 (May 2, 2002).
For U.S. Persons with investment income, private placement life insurance provides for compliant, […]
