New Reporting for Specified Foreign Financial Assets
Effective for tax years starting after March 18, 2010, new Sec. 6038D requires individual taxpayers to report any interest in “specified foreign financial assets” if the value of these assets in aggregate exceeds an applicable threshold amount.
Published on August 24, 2012
Potential Pitfalls in PFIC Reporting
PFIC investors should be aware of new PFIC reporting requirements and should be alert to developments that may affect them.
Published on June 30, 2012
QEF Elections Under PFIC Rules
In enacting the PFIC rules in 1986, Congress created a complex and punitive tax regime for certain passive foreign investments that continues to plague U.S. taxpayers and their tax advisers.
Published on September 30, 2012
Passive Foreign Investment Companies
This item assesses various planning alternatives that may help U.S. taxpayers avoid the negative aspects of the PFIC regime, including qualifying electing funds, mark-to-market elections, and various planning strategy options.
Published on April 17, 2012
FATCA Adds Layer of Complexity, Penalty Exposure to Offshore Asset Reporting
This item highlights the provisions of FATCA that are most likely to affect U.S. tax practitioners and their clients—the taxpayer reporting provisions of new Sec. 6038D.
Published on March 18, 2013
Focus on Tax Avoidance Leads to Changes in Foreign Reporting Requirements
The use of information reporting to prevent tax avoidance has been a major focus of the current administration and the IRS.
Published on September 01, 2010
Tips for Preparing the Form 5471 for Controlled Foreign Corporations
This article gives an overview of the issues faced by practitioners when preparing Form 5471 and can serve as a roadmap to the potential problems and traps for the unwary
Published on January 28, 2011
Once the exclusive province of large accounting and law firms, now even the smallest firms must master cross-border tax issues.
Published on February 28, 2013
New Foreign Asset Reporting Rules
Practitioners need to be aware of the new requirements for reporting foreign assets and income and confirm that clients are complying.
Published on August 31, 2012