Entries by Manager

Incorrect or Delinquent Form 5471 Penalties

Various Form 5471 penalties are associated with failure to file Form 5471 or the filing of an incorrect Form 5471. In this article, I will describe the most important of these penalties. IRS Form 5471 The IRS Form 5471 is an extremely complex form that is used to satisfy the reporting requirements of two esoteric […]

FATCA Tax Lawyers Update: FATCA Financial Institution Definition

One of the key concepts in FATCA compliance is a “financial institution”. The definition of a financial institution (“FATCA Financial Institution”) is contained in the FATCA Model IGAs. In this article, I will explore some of the general concepts central to defining a FATCA Financial Institution. Four Types of FATCA Financial Institutions The concept of […]

Costa Rica Corporations and U.S. Tax Reporting

It has become common for U.S. citizens to engage in business abroad through a foreign corporation.  Costa Rica is definitely one of the most favored countries in Central America, partially due to its reputation for stability.  It is important to understand, however, that U.S. citizens who engage in business abroad through a foreign corporation must […]