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This article will explain Internal Revenue Code Section 338(g), which allows corporations, that buy a certain percentage of a target corporation’s stock and meet certain requirements, to make an election to treat the acquisition as an asset purchase instead of a stock purchase. In the right circumstances, a Section 338(g) election can be a very […]
According to Reuters and Sonntags Zeitung, U.S. officials are offering eleven Swiss banks (including Credit Suisse, Julius Baer, Basler Kantonalbank and HSBC Switzerland) a deal that allows them to avoid criminal prosecution in exchange for revealing details of their U.S. offshore business to the U.S. government. Allegedly, in exchange to dropping the criminal prosecution, the […]
On December 15, 2011, the Internal Revenue Service stated that it will soon release the final version of a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011. Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by […]
IRS Form 1065 (U.S. Return of Partnership Income) is an information return used to report the income, gains, losses, deductions, credits, and related items from the operation of partnerships. Partnerships generally do not pay taxes because they are pass-through entities. Instead, profits or losses, and related items, are reported by partners (typically based upon their […]
Whether an account is reportable for FBAR purposes can sometimes be a relatively complicated question. It is true that it is easy to see that foreign bank and investment accounts should be reported on the FBAR as long as all other requirements are met. It is also well-established that a gold bullion account is reportable […]