Large private companies will soon have to deal with an added compliance burden, the Reportable Tax Position (RTP) schedule is set to apply to all large companies from 1 July 2020 (ie the 2020-21 income tax year). The reportable tax position (RTP) schedule is a schedule to the company income tax return and requires large businesses to disclose their most contestable and material tax positions.
Read moreForeign Residents And The Main Residence Exemption
Foreign residents beware, laws have been passed to restrict your access to claim the CGT main residence exemption on the sale of your home, except in some limited circumstances. This applies to any person that is not an Australian resident for tax purposes at the time of disposal (ie when the contract is signed to sell the property).
Read moreReporting US Single Member LLCs with Foreign Ownership
By Bethany Bouw, CPA
If you are a foreign person who has a US single member LLC, there are some new developments that you should be aware of for tax year 2017. Reporting policies regarding foreign ownership of single-member LLCs have recently changed. First and foremost, it is important to know your status – US or foreign. To determine this, you should check the IRS rules and contact a lawyer.
Read moreInternational Tax Technical Update- July 2018
What is BEAT?
Enacted as part of the Tax Cuts and Job Act (TCJA), the new “base erosion and anti-abuse tax” (BEAT) can apply to certain corporations that make “base erosion payments” paid or accrued in taxable years beginning after December 31, 2017. Read more
International Tax Technical Update- June 2018
IRS Offers Limited Relief to Certain Taxpayers Subject to the Section 965 Transition Tax
June 2018
Summary
On June 4, 2018, the Internal Revenue Service (IRS) announced that it will provide penalty relief to certain taxpayers subject to the Section 965 transition tax, and provided additional information for individuals subject to the Section 965 transition tax regarding the due date for relevant elections. Read more
The Basics of Form 3520
Form 3520 is required for many U.S. taxpayers with international activity. However, there is still a lot of confusion regarding the basics of the form.
By Bethany Bouw, CPA
Many taxpayers with international activity are becoming more familiar with informational reporting on foreign bank accounts, foreign corporations, and foreign financial assets. However, many still struggle with certainty when it comes to reporting transactions with foreign trusts or receipt of foreign gifts/bequests on Form 3520. As with most foreign informational reporting, this is not a form to be ignored or taken lightly as it carries significant penalties. Read more
Foreign Reporting: Changing Landscape for Forgetful Filers
Changes are on the way for anyone who misses a foreign tax filing deadline.
By Bethany Bouw, CPA
Big changes are coming for those who have missed a foreign filing requirement. As we have previously noted, there are a variety of procedures for becoming compliant. One of those methods will soon be closing, and this may signal additional changes on the horizon. Read more
Royal Wedding Excitement for the IRS
International marriages may be full of romance, but they also lead to complex tax situations that not even royals are immune to.
By Bethany Bouw
Many young, American women perhaps used to imagine what it might be like to marry a prince and live in a faraway kingdom. As the news has been widely covering, one American is about to have that dream come true. While Meghan Markle prepares for her new fairytale life, she will also be facing the many tax pitfalls of an international marriage. Even those who marry their foreign “prince” and move abroad will have to consider some of the same situations Ms. Markle must now deal with. Here are ten tips for those who, like Ms. Markle, will marry a non-resident and non-citizen, and move abroad. Read more
How do I Prove US Residency for Foreign Purposes?
By Bethany Bouw
Often when doing business or living overseas, foreign countries ask people to prove that they are US residents for tax purposes to eliminate or reduce foreign tax withholding. You may need residency certification to claim tax treaty benefits or exemptions from value added tax (VAT). Doing so is not as simple as showing a copy of your driver’s license or other government issued identification. Instead, there is an important process you must follow to obtain the proper documents which prove your US residency to foreign jurisdictions.
Read moreInternational Tax Technical Update- April 2018
CHANGES IN SECTION 965 SPECIFIED FOREIGN CORPORATIONS’ TAX YEARS
Summary
On February 13, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) issued Rev. Proc. 2018-17 (the “Rev. Proc.”). The Rev. Proc. provides additional guidance under Section 965, Treatment of deferred foreign income upon transition to participation exemption system of taxation, as amended by the “Tax Cut and Jobs Act,” which was enacted on December 22, 2017. In particular, the Rev. Proc. provides guidance regarding certain changes in Section 965 specified foreign corporations’ tax years. Read more