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On September 8, 2017, the IRS announced that the 4th Quarter 2017 underpayment and overpayment interest rates will remain the same as they were in the third quarter of 2017. The IRS underpayment interests also govern the PFIC interest rates under the default Section 1291 method of calculation. PFIC interest rates are very important not […]
Specified Foreign Financial Assets is one of the most important terms in contemporary US international tax law. In this article, I will explore what these Specified Foreign Financial Assets are and why they play such an important role in modern US international tax compliance. Specified Foreign Financial Assets and FATCA In order to understand the […]
The recent introduction of the new concept of Specified Domestic Entity by the IRS represents a major expansion of the application of FATCA to US businesses and US trusts. For tax years beginning after December 31, 2015, a domestic corporation, partnership or trust classified as a Specified Domestic Entity must file FATCA Form 8938 with […]
US taxpayers who own accounts outside of the United States should remember that, in order to open a new account (even if you already have an existing account), foreign banks throughout the world require the submission of various documents pursuant to FATCA. In this legal note, I am providing a list of the documents required […]
On July 20, 2017, the US Department of Justice announced that Mr. Teymour Khoubian was indicted by a federal grand jury in the Central District of California for corruptly endeavoring to impede the internal revenue laws, filing false tax returns and filing false FBARs regarding his German and Israeli bank accounts and making false statements […]