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This essay is concerned with a situation where the IRS audits your quiet disclosure of foreign assets and foreign income. The IRS audit can be an absolute nightmare in this case. Not only will the audit examine the accuracy of the disclosure, but the IRS may actually raise the issue of willful and non-willful FBAR […]
On November 9, 2016, the Ukrainian government authorized the Ukrainian FATCA Agreement for signature. Let’s explore this new development in more depth. Ukrainian FATCA Agreement and FATCA Background The Ukrainian FATCA Agreement is one of the many bilateral FATCA implementation agreements signed by the great majority of jurisdictions around the world. The Foreign Account Tax […]
The Russian Ministry of Finance (“MOF”) recently issued Guidance Letter 03-04-06/64102 (dated October 31) regarding the taxation of gifts from Russian legal entities to nonresidents (i.e. the Russian taxation of gifts to nonresidents). This Letter will have a direct impact on the tax planning for Russians who are tax residents of the United States. Russian […]
Who is considered to be a Milwaukee FBAR Lawyer? This is a question that is important to all residents of Milwaukee, Wisconsin. Let me try to answer this question. Milwaukee FBAR Lawyer Definition: Legal FBAR Services Provided in Milwaukee, Wisconsin The term Milwaukee FBAR Lawyer includes two broad categories of international tax lawyers. The first […]
FATCA PFIC Reporting is an important feature in today’s U.S. tax compliance. In this article, I will focus on the explanation of the FATCA PFIC Reporting requirement for U.S. shareholders of a PFIC. FATCA PFIC Reporting: FATCA Background The Foreign Account Tax Compliance Act (“FATCA”) is contained in Chapters 1471–1474 of the Internal Revenue Code […]