We are continuing our series of articles on the Specified Domestic Entity definition. In previous articles, I already explained what entities are considered to be domestic and what kind of foreign assets are included in the Specified Foreign Financial Assets. In this article, I would like to introduce the key part of the definition of […]
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Specified Individual is a key tax term that must be correctly understood in order to properly identify the persons who are required to file FATCA Form 8938. In this brief article, I will describe the general definition of a Specified Individual for Form 8938 purposes. Specified Individual: FATCA Form 8938 Background In 2010, one of […]
This is the second article from the series of articles concerning the definition of a Specified Domestic Entity. Today, I will explore what business entities are considered to be “Domestic”. Specified Domestic Entity Background Information Specified Domestic Entity is a new category of FATCA Form 8938 filers. Under FATCA, Form 8938 has to be filed […]
On January 8, 2018, the US Treasury Department published a list of boycott countries. Let’s analyze what is meant here by Boycott Countries. Boycott Countries: The Meaning of Boycott Under IRC Section 999(b)(3) IRC Section 999(a)(3) requires the Department of the Treasury to publish (at least on a quarterly basis) a current list of countries […]
On January 3, 2018, a decision of the Swiss Federal Court (the nation’s highest court) dated December 18, 2017, was published, prohibiting automatic disclosure of the Swiss bank staff details to the IRS and the US DOJ. Let’s analyze this decision in more detail. Disclosure of Swiss Bank Staff Details: History of the Case The […]