Foreign Accounts Compliance Blog

Mysterious Form 926

The United States taxes its citizens and residents on their worldwide income.  The Internal Revenue Service requires the filing of ...
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Shareholders in Closely-Held Foreign Corporations: Beware Form 5471

A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return ...
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Required Reporting of Foreign Financial Accounts

U.S. persons are required to report to the United States government concerning foreign financial accounts. A “U.S. person” is a ...
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Why You Need an Attorney in Charge of Your Foreign Accounts Compliance Case

Accountants commonly send an “organizer” to a client with instructions to complete and sign it and return it to the ...
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Compliance Required of U.S. Persons Concerning Foreign Financial Accounts

U.S. persons are subject to compliance obligations concerning foreign financial accounts under two statutes, the Internal Revenue Code and the ...
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Reporting Horrors of Foreign Mutual Funds (“PFICs”)

U.S.-based mutual funds annually issue to each of their shareholders a Form 1099 reporting the shareholder’s share of interest, dividends, ...
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You May Only Need to File Delinquent FBARs

Many U.S. persons are alarmed upon learning of their reporting obligations with respect to foreign financial accounts.  Those obligations include ...
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Beneficial Ownership, Income Tax, and FBARs

For U.S. income tax purposes, ownership of property means beneficial ownership.  Only the beneficial owner of property is required to ...
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U.S. Persons’ Reporting Obligations Regarding Foreign Financial Assets

The United States imposes reporting obligations upon U.S. persons with respect to their worldwide income and financial assets.  The reporting ...
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Passive Foreign Investment Companies: U.S. Clients Should Consider Tax Compliance

Foreign mutual funds, known as passive foreign investment companies or “PFICs,” pose significant compliance burdens for U.S. taxpayers.  Click here for the ...
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