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Every now and then, I encounter foreign business structures built on the incorrect belief that only direct ownership matters for U.S. tax reporting purposes in general and Form 5471 purposes in particular. In this essay, I broadly address the question of Form 5471 reporting with respect to indirect ownership of a foreign company (I am […]
The Treasury Department’s Financial Management Service (FMS) and the IRS are in the process of streamlining the lockbox network. Effective December 31, 2012, the IRS will close lockbox operations located in the Atlanta (State of Georgia) and St. Louis (State of Missouri) areas. Moreover, other P.O. box address closings affect addressed in Hartford, Connecticut and […]
In an earlier article, I discussed various penalties generally associated with late or inaccurate filing of Form 5471 (this form is required under IRC Section 6038(a) to provide information with respect to certain US shareholders of foreign corporations). These penalties are generally subject to “reasonable cause” exception and are not imposed in every case. Since […]
Starting January 1, 2013, Additional Hospital Insurance Tax (Additional Medicare Tax) will come to life as a result of section 9015 of the Patient Protection and Affordable Care Act (PPACA) (as amended). In essence, PPACA increased the existing Medicare tax for high-income earners. Currently, the Medicare tax rate is a flat 2.9% tax on all […]
The 2012 tax season is nearing. As calendar year 2012 is drawing to its end, the time for any tax planning is getting shorter and shorter. In order to do the tax planning properly, it is essential to know what tax bracket you are likely to be in and whether you can lower this bracket. […]