Every five years, the Bureau of Economic Analysis (BEA) requires U.S. persons (including entities) with certain foreign affiliates to file Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad, by a statutory deadline of May 29 or June 30, 2020. The COVID-19 pandemic has caused any postponement of the final BE-10 due date, which depends […]
On April 9, the IRS issued Notice 2020-23, expanding COVID-19 filing and payment relief to include most returns, tax payments and other time-sensitive actions with reporting deadlines falling on or after April 1, 2020, and before July 15, 2020. Prior to the issuance of Notice 2020-23, it was unclear whether the below international forms were […]
The IRS has clarified that the postponement of the due date for 2019 federal income tax filings and payments to July 15, 2020, also applies to installment payments of repatriation tax on foreign earnings and base erosion and anti-tax abuse tax (BEAT) that would otherwise be due on April 15. The Tax Cuts and Jobs Act […]
Art collectors who accumulate artwork over their lifetimes tend to have limited interest in selling any of the pieces in their collections, according to a recent study conducted by UBS. Instead, most collectors develop an emotional attachment to the artwork they acquire and prefer to display their collections in their homes for their own personal […]
The IRS recently rolled out Relief Procedures for Certain Former Citizens (expat relief procedures), which is intended to help some former U.S. citizens who renounced or intend to renounce their U.S. citizenship come into compliance with their outstanding U.S. tax and filing obligations without incurring additional liabilities. Background on Expatriation Exit Tax There are […]
For many foreign persons, the U.S. tax system can be a complicated web of conflicting rules and exceptions, making compliance difficult, at best. One of the more complex challenges concerns the manner in which the U.S. imposes tax on foreign persons for income tax and estate and gift tax purposes. In general, the U.S. presumes […]
U.S. real estate continued to attract foreign investors during the first half of 2019, thanks, in part, to a growing U.S. economy, low interest rates, and strong underlying fundamentals that support predictable cash flow and property appreciation. At the same time, the U.S. tax landscape has changed with the passage of the Tax Cuts and […]
Donations that U.S. taxpayers make directly to foreign charities usually will not qualify for income tax deductions unless those charities are registered with the IRS as tax-exempt entities or there is relief available under a bilateral income tax treaty. In the rare instances when these conditions are met, the charitable deduction is available only to […]
After 29 years, the U.S. government is making changes to its EB-5 visa program, which helps foreign citizens expedite U.S. residency in return for capital investment in commercial projects that create or preserve domestic jobs. Under new rules that go into effect on Nov. 21, 2019, it will become more expensive and more difficult for […]
In the summer of 2019, the U.S. ratified updates to international tax treaties with four of the country’s allies that had been awaiting Senate approval for nearly a decade. The move yielded a collective sigh of relief from multinational businesses and their shareholders in Spain, Switzerland, Japan and Luxembourg that had been operating in an […]