International Taxation
Doing Business in Russia
Below are some typical questions that may arise when a business owner is considering expanding operations into Russia. Please be advised the Q&A summary below is intended for general use only and should not be relied upon. When a business … read more
Doing Business in Italy
Below are some typical questions that may arise when a business owner is considering expanding operations into Italy. Please be advised the Q&A summary below is intended for general use only and should not be relied upon. When a business … read more
New ITIN Policy Change for 2013
Foreign taxpayers applying for an Individual Taxpayer Identification Number (ITIN) were hit with some strict application requirements during 2012. The IRS began to demand original identification documentation with Form W-7 or certified copies of documentation from the issuing agency. The … read more
New ID Number Requirement on Forms 5471, 8858, and 8865
An Employer Identification Number (EIN) has always been an optional entry on forms 5471, 8858, and 8865. However, the IRS has implemented a new form of identification number on these forms called a Unique Reference Identification number (URI). The URI … read more
New Reporting Requirements for Nonresident Alien Deposit Interest
Historically, the IRS has not required the reporting of bank deposit interest when earned by nonresident aliens and nonresident aliens have not been subject to U.S. tax on this income. The government has maintained this policy in order to encourage … read more
New Favorable Private Letter Ruling for a U.S. Taxpayer with A Bank Trust in Mexico
The IRS announced, by issue of a private letter ruling (PLR) on July 30, 2012, that a fideicomiso or Mexican Land Trust (“MLT”) is not a trust within the meaning of Regulation 301.7701-4(a). This conclusion relieved one taxpayer of an … read more
New ITIN Application Requirements
In the past when applying for an Individual Tax Identification Number (ITIN), applicants could send notarized copies of supporting documentation, such as their passport or birth certificate, with their W-7 application. The IRS is currently trying to strengthen and protect … read more
IRS Helps U.S. Citizens Abroad With U.S. Tax Compliance
The IRS understands that many U.S. citizens living overseas are becoming more aware of their tax filing obligations and want to comply with the law. The recent offshore voluntary disclosure programs have resulted in a large number of taxpayers coming … read more
United Kingdom Residents Investing in the U.S.
Non resident individuals investing in the U.S. may encounter many tax problems when their home country applies different tax treatment to an investment. One such example of this problem occurs when a United Kingdom investor becomes an owner or partner … read more
8938 Requirement for Business Entities Postponed
As a follow up to the blog Ringing In the New Year, the IRS just released the final version of Form 8938, Statement of Specified Foreign Financial Assets, and its instructions. Individuals must refer to these instructions to report specified … read more