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Category: International Planning (page 1 of 2)

Alexandre M. Denault & Jonathan E. Gopman – Treasury Department Extends Form 5472 Filing Requirements to Foreign-Owned Domestic Disregarded Entities

Treasury Department Extends Form 5472 Filing Requirements to Foreign-Owned Domestic Disregarded Entities

By: Alexandre M. Denault & Jonathan E. Gopman

On May 10, 2016, Treasury issued proposed regulations (the “Proposed Regulations“) which enable the Internal Revenue Service (the “Service“) to collect certain information about domestic disregarded … Continue reading

IRS to Hold Webinar on May 25 to Assist International Taxpayers; June Filing Deadlines Nearing for Most Americans Abroad

WASHINGTON — The Internal Revenue Service on Wednesday will hold a free online, web-based information session to assist U.S. overseas taxpayers in understanding their filing obligations.

The webinar will take place on May 25, 2016, from 1-3 p.m. EDT, (18:00-2100 hours UTC-0). To attend this webinar, taxpayers or tax professionals … Continue reading

IRS Issues Proposed Regs on Gifts + Bequests from Expatriates

The IRS has issued proposed regulations on September 9, 2015,  addressing taxation of US  citizens and residents receiving gifts/bequests from individuals who previously expatriated from the US.

The proposed regulations are broken into seven parts, which are as follows:

  • Section 28.2801-1 of the proposed regulations sets forth the general rules
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IRS Issues Internal FBAR Penalty Guidance To Ensure Consistency

Steve Schneider, at Goulston & Storrs writes about newly issued IRS Internal FBAR Penalty Guidance.  His post begins as follows:

Shortly before the annual June 30 FBAR filing deadline, the IRS issued penalty guidance for those that miss the foreign bank account reporting deadline. The purpose of the

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The Political Codification of Islamic Law: A Closer Look at the Draft Shi’I Personal Status Code of Iraq by Haider Ala Hamoudi

Haider Ala Hamoudi, of the University of Pittsburgh School of Law, has made available for download his article, published in the Arizona J. Int’l and Comparative Law, v. 32, No. 2 (2015), entitled “The Political Codification of Islamic Law: A Closer Look at the Draft Shi’I Personal Status Code of … Continue reading

FATCA in Canada: The Restriction of the Class of Entities Subject to FATCA by Roy A Berg, Paul Barba

Roy A. Berg and Paul Barba have published their article, “FATCA in Canada: The Restriction of the Class of Entities Subject to FATCA” which is available for download.  The abstract reads as follows:

This article provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for Canadians, and analyzes

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Dealing with Erroneous FATCA Inquiries

M. Robinson & Co writes about how to respond when a foreign bank asks your client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Your client can provide the information or your client can choose not to provide the information. … Continue reading

IRS Publishes Guide to Help IDES Enrollment under FATCA

The Internal Revenue Service published a guide to help financial institutions (FI), non-financial foreign entities (NFFE), Host Country Tax Authorities (HCTA) and U.S. withholding agencies who enroll in the International Data Exchange Service (IDES) to understand how IDES works and how to transmit Foreign Account Tax Compliance Act (FATCA) data … Continue reading

49th Annual Heckerling Institute on Estate Planning (Jan 14th)

The following are summaries of the presentations from the 49th Annual Heckerling Institute on Estate Planning. For the official brochure and list of events, see  http://www.law.miami.edu/heckerling/pdf/2014/heckerling-brochure.pdf. For the Heckerling reports, see http://www.americanbar.org/groups/real_property_trust_estate/events_cle/heckerling_reports.html.

M. Read Moore on Tax Administration and Procedural Rules for Estate Planners

Moore’s presentation focused on the … Continue reading

Being a Good Networker

Networking brings not only contacts but also investment and business in the future. Being a good networker first means to be shameless, and to get attention from people by praising them or by discovering similar interests or experiences. A second step is to speak out the right things, even about … Continue reading

CCA Draws Attention to Offshore Partnership with A U.S. Manager

Although a Chief Counsel Advice by IRS is not law, a most recent advice casted alert to non-U.S. partners. In determining the taxability of an offshore partnership with a U.S. manager through whom the partnership conducted all activities, the IRS found that the commercial lending and underwriting activities conducted through … Continue reading

Where Do You Call Home?: On the Issue of International Estate Planning

For those who spend significant amounts of their time in more than one state or more than one country, the answer to the  question “Where do you call home?” has significant consequences. Janet Brewer states that it is important for people and families who have multiple residences to take the time to … Continue reading

Tax Aspects Of Foreign Ownership Of US Residential Real Estate

Stuart T. Freeland, of Rackemann, Sawyer & Brewster, PC, writes about tax aspects of foreign ownership of US residential real estate.  His article notes that representation of foreign individuals who wish to purchase US residential property should include careful attention to the manner in which the income and gain from … Continue reading

Charles (Chuck) Rubin: Treasury Makes Life Easier for Holders of Canadian Retirement Account Interests

By: Charles (Chuck) Rubin


Summary: Treasury automates the process for U.S. taxpayers making an election to defer taxation of Canadian RRSPs and RRIFs and to eliminate some information reporting requirements as to those accounts.

U.S. persons are generally not subject to U.S. income tax on individual retirement accounts (“IRAs”) … Continue reading

Charles (Chuck) Rubin: No Informal Abandonment of Residency Allowed

By Charles (Chuck) Rubin

SUMMARY: The Tax Court rules against informal abandonment of resident status.

Individuals who are admitted to the US as lawful permanent residents (“green card” holders) are treated as U.S. residents for income tax purposes. Code section 7701(b)(1)(A)(i). As such they are subject to U.S. income taxes … Continue reading

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