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The Alternative Minimum Tax (the “AMT”) attempts to ensure that anyone who benefits from certain tax advantages pays at least a minimum amount of tax. Congress created the AMT in 1969, targeting higher-income taxpayers who could claim so many deductions they owed little or no income tax. The AMT provides an alternative set of rules […]
The Internal Revenue Service, Deputy Commissioner (International), Large Business and International Division (“LB&I”), announced certain organizational and administrative changes and transitional procedures in connection with the creation of the Advance Pricing and Mutual Agreement (“APMA”) program. Prior to February 26, 2012, the Advance Pricing Agreement (“APA”) program was part of the Office of the Associate […]
The U.S. Department of Treasure recently published its official currency conversion rates for December 31, 2011 (they are called “Treasury’s Financial Management Service rates”). These rates are important for many reasons, but one reason especially stands out for persons who are required to file the FBARs. The latest (January 2012) FBAR instructions require the use […]
The Foreign Account Tax Compliance Act (“FATCA”) produced a major catalyst for the usage of Form W-9 by the banks in order to identify whether their clients are U.S. taxpayers. This article explores the connection between the IRS Form W-9, FATCA and FBAR compliance. IRS Form W-9 The essence of the IRS Form W-9 is […]
General Obligations To Deposit Payroll and Income Tax Withholdings Under federal law, employers must withhold Social Security, Medicare and Federal income taxes from their employees’ paychecks and deposit them with the federal government (together with the employer’s own payroll tax contributions). In addition to the deposit requirements, the employers are also obligated to file Form […]