The Internal Revenue Service, Deputy Commissioner (International), Large Business and International Division (“LB&I”), announced certain organizational and administrative changes and transitional procedures in connection with the creation of the Advance Pricing and Mutual Agreement (“APMA”) program. Prior to February 26, 2012, the Advance Pricing Agreement (“APA”) program was part of the Office of the Associate [...]

The U.S. Department of Treasure recently published its official currency conversion rates for December 31, 2011 (they are called “Treasury’s Financial Management Service rates”). These rates are important for many reasons, but one reason especially stands out for persons who are required to file the FBARs. The latest (January 2012) FBAR instructions require the use [...]

The Foreign Account Tax Compliance Act (“FATCA”) produced a major catalyst for the usage of Form W-9 by the banks in order to identify whether their client are U.S. taxpayers. This article explores the connection between the IRS Form W-9, FATCA and FBAR compliance. IRS Form W-9 The essence of the IRS Form W-9 is [...]

General Obligations To Deposit Payroll and Income Tax Withholdings Under federal law, employers must withhold Social Security, Medicare and Federal income taxes from their employees’ paychecks and deposit them with the federal government (together with the employer’s own payroll tax contributions). In addition to the deposit requirements, the employers are also obligated to file Form [...]

In January of 2012, the IRS issued a new version of the Treasury Form TD F 90-22.1, popularly known as the “FBAR” (the Report on Foreign Bank and Financial Accounts). This is a third revision of the FBAR in less than one year.  In March of 2011, the IRS made substantial changes to the FBAR [...]

Under the current U.S. tax law, canceled debt is normally taxable to you, but there are exceptions. One of those exceptions is came into existence under the Mortgage Forgiveness Debt Relief Act of 2007. Under this law, married homeowners whose mortgage debt is partly or entirely forgiven during tax years 2007 through 2012 may exclude [...]

On February 23, 2012, the IRS announced that the underpayment and overpayment interest rates will remain the same for the calendar quarter beginning April 1, 2012. The rates will be: three (3) percent for overpayments (two (2) percent in the case of a corporation) three (3) percent for underpayments five (5) percent for large corporate [...]

On February 23, 2012, the Internal Revenue Service released revised Form 941 enabling employers to properly report the newly-extended payroll tax cut benefiting nearly 160 million workers. The IRS needed to revise Form 941 due to the Middle Class Tax Relief and Job Creation Act of 2012 (enacted on February 22, 2012). Under the new law, [...]

A W-2 is required to be filed by every employer who is engaged in a trade or business paying remuneration (including noncash payments) of $600 or more for a year in which services are performed by an employee.  A W-2 must be filed for each employee for whom income, Social Security, or Medicare tax was [...]

For the U.S. tax compliance purposes, it is very important to properly classify foreign business entities, because there are special IRS requirements associated with ownership of foreign business entities. For instance, a list of various tax forms is tied to particular classification (for example, certain U.S. taxpayers are required to file Form 5471 with respect [...]