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 […]
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 […]
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 […]
The overhaul of the U.S. tax code was signed into law at the end of 2017, yet many taxpayers are continuing to conduct business as usual, paying little attention to how the new law impacts their tax liabilities for 2018 and beyond. To be sure, the Tax Cuts and Jobs Act (TCJA) in its original […]
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 U.S.’s different treatment of foreign persons for income tax and estate and gift tax purposes. In general, the U.S. presumes foreign persons to be […]
Effective May 13, 2019, the IRS will only issue Employer Identification Numbers (EINs) to entities whose applications name a responsible party who has a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). No longer will the IRS accept Form SS-4 or online applications from entities that use their existing EINs to obtain additional […]