Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities

Morgan Klinzing, of Pepper Hamilton writes about new filing requirements for foreign owned disregarded entities. His article begins as follows:

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions.If a non-U.S. person (individual or corporation) owns

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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 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