You were honored when your close friend or family member asked you serve as the executor of their estate. You did not realize the amount of the work associated with the task. You also didn't realize you were personally financially liable for your actions as an executor. If you are...
The California Waters Edge Election
What is the California Waters Edge Election and how does that affect taxation for certain taxpayers with offshore business income and assets? The California water's edge election was established in 1986 and was designed to restrict California's "application of the worldwide combined reporting method of determining income from California sources." Instead...
US Treasury and IRS Update Guidance on PFICs and CFC Investments
Recently the US Treasury Department and the Internal Revenue Service (IRS) released new guidance on PFICs and CFC investments for a Regulated Investment Company (RIC). Under US tax law a corporation can qualify as a Regulated Investment Company for a given tax year only when 90% or more of...
Brazilian FATCA Offshore Disclosures Net $4 Billion US
The deadline for Brazil's offshore account, income and asset reporting passed last week. The Brazilian Federal Revenue Secretariat (SRF) - Brazil's equivalent of the IRS - claims more than $4 Billion (US) in revenues from voluntary disclosures much like the US Offshore Voluntary Disclosure Program or OVDP. The Brazilian FATCA offshore...
Argentina’s Aggressive Offshore Tax Strategy Results in Threat to Account Holders of Major US Bank
The implementation of global forms of the US FATCA tax initiative, often referred to as GATCA (Global FATCA) continue to gain steam in Central and South America. This week a major US bank threatened to close the accounts of Argentinians with "undeclared funds." JP Morgan announced this week that "all funds...
CRS GATCA and the OECD – The Impact of FATCA
There are a lot of new acronyms in the world of international taxation. What do CRS GATCA and the OECD have to do with FATCA and offshore bank accounts? What impact has FATCA had upon other sovereign entities around the world? If are a US taxpayer and you have offshore...
World Leaders Developing New Standards to Identify and Exchange Beneficial Ownership Information
The goal of financial transparency worldwide is gaining momentum. The US FATCA initiative has spawned like legislation around the globe. The benefit of taxation derived from the discovery of offshore taxpayer financial accounts and interests has world leaders developing new standards to identify and exchange beneficial ownership information for bank...
IRS Updates Guide for Business Tangible Property Regulations
Business owners should be cautious with how they manage business tangible property regulations - especially when faced with an IRS audit. Most US business taxpayers completed the implementation of the IRS Business Tangible Property Regulations last year. These new regulations were a guide to help business owners and their...