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US taxpayers who own Hungarian bank accounts may have to comply with a large number of US tax reporting requirements. In particular, they need to be concerned about reporting income generated by their Hungarian bank accounts as well as disclosing the ownership of these accounts on FBAR and Form 8938. Other requirements may apply, but […]
On June 5, 2019, the Internal Revenue Service announced 2019 Third Quarter IRS Interest Rates. This quarter, the IRS interest rates will be reduced for the first time in years. 2019 Third Quarter IRS Interest Rates: 3rd Quarter and Interest Rates Defined Third quarter of 2019 begins on July 1, 2019 and ends on September […]
On May 31, 2019, the IRS released a Private Letter Ruling (“PLR”) on the extension of time to make an election to be treated as a disregarded entity for US tax purposes under Treas. Reg. Section 301.7701 (26 CFR 301.7701-3). Let’s explore this PLR 201922010 in more detail. PLR 201922010: Fact Pattern PLR 201922010 deals […]
The 2017 Tax Reform created the Internal Revenue Code Section 965, which requires US shareholders of foreign corporations to pay a new transition tax (hereinafter, “IRC 965 Tax”) in certain circumstances. In this short article, I will introduce the readers to the IRC 965 Tax. IRC 965 Tax: Taxpayers Who Are Targeted by the New […]
On April 16, 2019, the IRS Large Business and International division (LB&I) announced the approval of three additional compliance campaigns. Let’s discuss in more detail these April 2019 IRS compliance campaigns. April 2019 IRS Compliance Campaigns: Background Information In the mid-2010s, after extensive planning, the IRS decided to move LB&I toward issue-based examinations and a […]