Expatriation SNAFU! Form 5471 Not “Substantially Complete”
My earlier blog posting covered some of the basics of Form 5471, “Information Return of U.S. Persons with Respect to Certain Foreign Corporations”. The Form is notoriously complex and consumes...
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“Cash” Buyers of US Real Estate – More Under FinCEN’s Microscope
Last year, FinCEN started to look more closely at anonymous cash buyers of prime US real estate. The agency’s concern was that real estate purchases made without bank financing through shell companies...
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Your “Loan” to a Foreign Corporation
What happens if you make a loan to a foreign (non-US) corporation and the Internal Revenue Service (IRS) later determines that the “loan” should not be treated as a “loan” for US tax purposes?...
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Do I Hold “Debt” or “Equity” in a Foreign Corporation? (Factors, Part I)
My earlier blog post detailed some of the tax consequences that could occur when a taxpayer makes, what he thinks is a “loan” to a foreign corporation, but that the Internal Revenue Service (IRS) later...
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Do I Hold “Debt” or “Equity” in a Foreign Corporation? (Factors, Part II)
My last two blog posts, here and here, examined some of the tax consequences that could occur when a taxpayer mistakenly classifies an advance to a foreign corporation as a “loan” but that the Internal...
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Foreign Corporations Spared in IRS Final “Debt” / “Equity” Regulations
Code Section 385 deals with the classification of certain interests in corporations as either “debt” or “equity” interests. The Code Section was originally enacted over 40 years ago, and later amended...
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PFIC Break for Some – No Need to File Annual Form 8621
Heartfelt thanks to Richard S. LeVine, J.D., LL.M. who emailed me to point out that the Internal Revenue Service (IRS) had just recently issued final “Passive Foreign Investment Company” (PFIC)...
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House Republicans – Death Knell for Subpart F/ Americans Abroad Barely...
House Republicans set out to deliver a bold, pro-growth policy agenda focused on addressing important concerns of the American people which included how changes to the tax law could grow the economy....
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IRS Has a New Audit Strategy – Focus OVDP Withdrawals and Declines
Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division now has a new audit strategy known as “campaigns.” For the past several years, the LB&I Division has attempted...
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So, Sir Patrick Stewart Wants to Become a US Citizen?
Sir Patrick Stewart (yes, despite rumors to the contrary, I know you are still alive), I understand you want to become a US citizen so you can “fight” President Trump (in your inimitable “X-Men” star...
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