New form 8858 filing requirements for foreign rentals and businesses

Effective beginning in 2018, the IRS expanded the scope of those U.S. persons required to file a Form 8858 with their tax return.  In addition to reporting foreign disregarded entities (FDEs), foreign branches (FBs) must now be reported on the 8858. Don’t miss: Planning for stimulus What is considered a foreign branch for purposes of …

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Are you choosing the best tax preparer?

It is in the taxpayer’s best interest to choose a tax preparer that best suits their needs. After all, responsibility does fall on the taxpayer for the information disclosed on their tax return, not the tax preparer. There is a large assortment of tax preparers available to assist you with your 2020 taxes, but are …

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More clarity for partnership international reporting

Are you invested in a partnership that provides you with an enormous number of documents attached to the K-1? Well the recent form changes are meant to extract some of the long narratives to describe the type of foreign income items being allocated to you and streamline such disclosures to specific Schedules on the K-1. …

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Updates to GILTI High-Tax Exception regulations

The IRS issued final regulations to the High-Tax Exception (HTE) for Global Intangible Low-Taxed Income (GILTI) on July 20, 2020.  Although these final regulations are similar to the proposed regulations issued in June of 2019, they contain some modifications such as allowing an annual election rather than a five-year binding election and allowing for retroactive …

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Court ruling holds decedent’s estate liable for FBAR penalties

Dean Danielson was a U.S. citizen who formed a corporation called Sugar Creek in the 90’s. The company was in the business of selling Swiss annuities, and he opened two foreign bank accounts (one in Canada and one in Lichtenstein) in the company’s name. In the years 2006 through 2009, the amounts in those bank …

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Transfer tax and foreign items adjust for inflation in 2021

Transfer tax and foreign tax figures are among those that are adjusted annually for cost-of-living increases. Thomson Reuters Checkpoint has calculated these figures for the year 2021 using the chained Consumer Price Index from August 2020. Don’t miss: Reasonable compensation for S-Corporation shareholder employees The annual gift tax exclusion will remain at $15,000 and the …

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Taxes and international boycott operations

U.S. taxpayers who have operations in, with, or related to certain countries participating in boycotts not sanctioned by the U.S. government may be required to report such operations to the IRS. Willful failure to file may result in large penalties, including $25,000 and/or imprisonment. Don’t miss: International tax reform update As of October 10, 2019, …

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Claiming treaty benefits

The United States has income tax treaties with many foreign countries. A treaty has benefits in that they may reduce the U.S. income tax of a resident of a foreign country. The reduced tax rates or exemptions vary between each country and each type of income. Don’t miss: IRS releases FAQ’s for sick foreigners claiming …

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Foreign gift reporting requirements

Generally speaking, the United States imposes gift tax on all gifts above a certain threshold. In other words, the reporting of a foreign gift must meet a certain threshold to be taxable. But in general, in the case of a nonresident and not a citizen of the United States, gift tax shall apply to a …

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