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If the ‘Specified Individual‘ is a current beneficiary of the trust then the trust is considered a ‘Specified Domestic Entity’. What it means is that any type of a US Beneficiary will make the trust a Specified Domestic Entity by definition; it’s very easy for a ‘Specified Trust’ to be a Specified Domestic Entity. Now […]
Let’s put it put it this way: a majority of foreign companies would be considered as foreign corporations under US Law except the check-the-box rules, that’s a major exception. You can choose what the company will be irrespective of its default classification under US Tax Law. So, in your example if the US Company, a […]
But you have to be conscious of the fact that if you’re going to change the classification of a foreign entity, you have to be extremely careful because the very fact that you change the classification of an entity could result in huge, absolutely huge tax liability to your clients. I’ll give you an example […]
Hello and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd. And today we are continuing our blog from the Czech Republic in Karlovy Vary. And in making this video one of my clients was a fan of James […]
FBAR requirements are a separate requirement form from Form 8938. The FBAR requirement does not replace the requirement to file a Form 8938; it’s in addition to. So, if you own the assets individually, you might have to file a Form 8938 and FBAR at the same time. And not really at the same time […]