| 
On November 23, 2021, the IRS announced that the First Quarter 2022 IRS interest rates on overpayment and underpayment of tax will not change from the Fourth Quarter of 2021. This means that, the First Quarter 2022 IRS interest rates will be as follows: Internal Revenue Code (“IRC”) §6621 establishes the IRS interest rates on […]
Ownership of a Controlled Foreign Corporation (“CFC”) presents unique income tax challenges under US international tax law. One of them is the fact that US shareholders of a CFC may have to recognize CFC income on their US tax returns beyond what is required under US domestic tax laws. In this article, I will introduce […]
It is a common, almost default practice in Brazil to invest in Brazilian mutual funds. While this practice is perfectly innocent for majority of Brazilians, it may present a huge compliance issue for Brazilians who are also US taxpayers. The problem is that this type of an investment draws at least two important US tax […]
As if they were not high enough, the US Congress has obligated the IRS to adjust FBAR civil penalties for inflation on an annual basis. In this article, I will provide a broad overview of the current FBAR penalty system and describe the current 2021 FBAR civil penalties. 2021 FBAR Civil Penalties: Overview of the […]
US international tax attorney discusses FBAR and FATCA compliance concerning Pakistani bank accounts.