international tax Tag

Currently, a foreign-owned US disregarded entity generally owes no US tax reporting unless the entity is engaged in a US trade or business or has certain types of US-source income. However, such a disregarded entity can disguise its owners, allowing for abuses like tax evasion....

Twitter’s upcoming IPO has brought increased attention to the company and its international tax affairs.  Twitter’s SEC filings have brought to light a number of Irish and Dutch subsidiaries, so it appears the company may follow Apple and Google’s lead in adopting a Double Irish...

July 5, 2012 The Foreign Account Tax Compliance Act (FATCA), enacted as part of 2010 Hiring Incentives to Restore Employment (HIRE) Act, is a reporting regime designed to ensure US citizens and residents pay appropriate US taxes on specified foreign financial assets. FATCA focuses on foreign...

Internal Revenue Code (I.R.C.) Section 7874 regulates corporate and partnership inversions. An “inversion” occurs when an entity elevates a subsidiary in a low-tax jurisdiction (e.g., Bermuda) to a parent position, inverting the previous affiliation and becoming a subsidiary of the foreign-headquartered entity. By relocating one’s...

All United States persons, including citizens, green card holders, and individuals considered US residents based on the duration of their stay in the United States, are required to annually report their ownership of, or signature authority over, foreign bank accounts. The form for such reporting...

In 2010, the U.S. government enacted the Foreign Account Tax Compliance Act (FATCA), containing provisions that would require, starting in 2013, foreign financial institutions (FFIs) to provide to the IRS the personal information of any United States persons holding accounts at that FFI. See https://rroyselaw.com/blog1/2012/01/12/third-offshore-voluntary-disclosure-program-announced-by-irs/.The...

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