International Taxation
Tax Planning for a Foreign Assignment
Many taxpayers do their homework when it comes to planning for their domestic and international income tax obligations when they are going overseas. Often the consulting begins and ends with income tax planning only. The United States has entered into … read more
Offshore Payment Card Reporting
The IRS intends to amend Internal Revenue Code Section 6050W that requires annual information reporting for payment card transactions beginning January 1, 2011. The amendment serves to respond to concerns about the administrative burden of the new reporting requirements. Section … read more
IRS Reopens Offshore Disclosure Program
The IRS has given taxpayers yet another chance to step forward and report income from offshore accounts without facing criminal prosecution. The first two Offshore Voluntary Disclosure Initiatives (OVDI) that were launched in 2009 and 2011 brought in over $4.4 … read more
Form 8832 “Entity Classification Election” Approval
After filing Form 8832, Entity Classification Election, the IRS will send a letter of acceptance or rejection usually within 60 days. If the election is accepted, you are required to attach a copy of Form 8832 to your tax return … read more
Ringing in the New Year
As we look to the hope and promise that a new year may offer, we must also look to the IRS website for new international tax reporting changes. IRS mandates new reference ID requirements for foreign information returns The IRS … read more
New Benefit for U.S. Persons Living in the UK
Pursuant to Revenue Ruling 2011-19, the IRS confirmed that the UK remittance based charge is eligible for a foreign tax credit in the US. A taxpayer wishing to have the U.S. tax offset must comply with all other aspects of … read more
Are You In Compliance With Your Foreign Reporting Obligations? If Not, Read On…
The IRS is offering a second voluntary disclosure opportunity for those with offshore accounts. Those who wish to comply with the disclosure must do so by August 31, 2011. The program requires taxpayers to bring all tax filings up to … read more
Does Your Partnership Have a Foreign Partner?
If you have a foreign partner in your partnership, you may need to pay a withholding tax on that partner. A partnership that has income effectively connected with a U.S. trade or business is required to pay a withholding tax … read more