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On March 13, 2015, the IRS announced that the underpayment and overpayment interest rates for the calendar quarter beginning April 1, 2015, will remain unchanged. The rates will be: three (3) percent for overpayments [two (2) percent in the case of a corporation];three (3) percent for underpayments;five (5) percent for large corporate underpayments; andone-half (0.5) […]
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 […]
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 […]
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 […]
Choosing your lawyer among International Tax Lawyers Austin Texas is not a simple task, especially for a US taxpayer thinking about doing an offshore voluntary disclosure. One of the critical questions often arises is whether it is better to retain an international tax lawyer in Austin or in Minneapolis if you live in Austin? It […]