Subpart F Income- Traps for the Unwary
Under the IRS “Subpart F” rules (26 USC Part III, Subpart F), certain categories of income of controlled foreign corporations (“CFCs”) must be included [...]
IRS Issue Statistics for CFC Holdings; Importance of Form 5471 Grows
On March 6, 2013, the IRS issued statistics for the tax year 2008 with respect to foreign corporations controlled by U.S. corporations. These statistics [...]
OVDP Offshore Penalty and Signatory Authority Accounts
The taxpayers who enter into the IRS Offshore Voluntary Disclosure Program (“OVDP”) often have failed to file an FBAR to report an account over [...]
FATCA at Home: Crackdown on Foreigners’ Accounts in U.S. banks
As the IRS engages in negotiations with foreign governments to implement FATCA (Foreign Account Tax Compliance Act) overseas, there is a rising pressure from [...]