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In 2014, the IRS issued both final (T.D. 9667), and proposed (REG-114942-14) regulations amending the rules for filing Form 5472, (“Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business”). Form 5472 is used to provide the information required under Internal Revenue Code (“IRC”) Sections 6038A […]
Following the implementation of Foreign Account Tax Compliance Act (“FATCA”) on July 1, 2014, foreign banks around the world started sending out FATCA Letters to their US (or suspected US) customers who had accounts on record prior to as well as on June 30, 2014. In a previous article, I discussed the reason for FATCA […]
The long-awaited Brazil FATCA IGA (Intergovernmental Agreement) was finally signed on September 23, 2014. This is an event of high importance and, in this article, I would like to explore Brazil FATCA IGA in more detail. FATCA & Model Treaties FATCA (“Foreign Account Tax Compliance Act”) was signed into law in 2010. This is a […]
Less than a month ago, Irish Finance Minister Michael Noonan announced in an address introducing the 2015 budget to the Irish parliament that the country will be changing its tax code to require all companies registered in Ireland to be tax residents, thereby ending the so-called Double Irish loophole utilized by many US companies and […]
On September 22, 2014, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued Notice 2014-52, “Rules Regarding Inversions and Related Transactions” in the wake of recent inversions. In previous articles on Hopscotch loans and de-control of CFCs, we covered certain aspects of the new regulations to be issued. This article will […]