Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer? A Passive Foreign Investment Company or PFIC is a foreign corporation...
ABCast Episode 7 – FBAR and Foreign Asset Reporting to the IRS
We invite you to listen to our latest podcast, ABCast Episode 7 - FBAR and Foreign Asset Reporting to the IRS with Janathan Allen. In this podcast, Jan and Neil discuss the impact of FATCA on US taxpayers worldwide and associated reporting requirements to the IRS. Many US taxpayers are...
International Business and Offshore Investment and Banking Create Genuine Risk with the IRS
International business and offshore investment and banking create genuine risk with the IRS. This extends to the ownership of real estate outside of the US and other offshore related financial activities which raise red flags with the IRS. The past several years have brought rapid change in FATCA compliance and...
IRS has Released Finalized PFIC Regulations
The IRS has released finalized PFIC regulations as well as proposed new regulations which relate to the modification of PFIC rules. A few years ago the IRS issued temporary rules regarding ownership of Passive Foreign Investment Companies (PFIC) and how shareholders in these companies would be taxed. The IRS has finalized...
What is a PFIC and How Do Offshore Investments Lead to Higher Taxation?
What is a PFIC and how could your offshore investments actually lead to a higher taxation rate on earned income? A Passive Foreign Investment Company or PFIC is classified by the IRS in two ways: 75% or more of the income from the foreign corporation is classified as "passive income,"...
Streamlined Domestic Offshore Procedures Still a Viable Option for Foreign Nationals
The offshore focus of the US Treasury Department and the IRS is well documented, and many questions remain for those who have either yet to take action to come into compliance with IRS FBAR and offshore reporting or for foreign nationals who may not have realized the requirements. Our office...
Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing
Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute. The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...