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US persons are taxed on their worldwide income, but are allowed a foreign tax credit (FTC) for foreign taxes paid. In most cases, the FTC gives taxpayers a dollar-for-dollar credit against their US tax liability. However, the FTC may be limited for Alternative Minimum Tax (AMT) purposes in order to ensure that a taxpayer’s US […]
On July 18, 2011, the Financial Crimes Enforcement Network (FinCEN) announced that it has developed an electronic filing system that will accept Form 114 formerly Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (commonly known as “FBAR”). Once the FBAR is filed electronically, the filers will receive an acknowledgment of each report […]
Since the enrollment into the 2011 Offshore Voluntary Disclosure Initiative (“OVDI”) closed on September 9, 2011, I have been asked repeatedly by new and prospective clients about their post-OVDI options – i.e. is there a voluntary disclosure option for clients who were not able to enroll into the program by the September 9 deadline? The […]
Do you own, or are you thinking of owning, foreign rental property? While investing in foreign rental property may have many advantages and can be a potentially lucrative enterprise, you should be aware that, among other aspects, the IRS treats rental properties located outside of the United States differently than rental properties in the United […]
IRS Form 8865 (“Return of U.S. Persons with Respect to Certain Foreign partnerships”) is used to report information required under IRC section 6038 (reporting with respect to controlled foreign partnerships), IRC section 6038B (reporting of transfers to foreign partnerships), and IRC section 6046A (reporting of acquisitions, dispositions, and changes in foreign partnership interests) for those […]