US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
What this talk will cover - What is going on! What are trade assets? Who needs finance? Who can or wants to finance them? Who else could finance them? How to become involved in trade finance assets? Legal issues...more
In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more
1. Specific Financial Asset Types - 1.1 Common Financial Assets - A wide range of asset classes have been securitised by Irish special purpose entities (SPEs): residential mortgages; commercial mortgages; auto loans;...more
The obligation under the EU Foreign Subsidies Regulation (FSR)[1] to report M&A transactions involving parties which have benefited from foreign financial contributions enters into force today. This creates an additional...more
Financial Asset Managers Charged in $1.2 Billion International Money Laundering Scheme - On July 12, 2022, two financial asset managers from Switzerland and Argentina were charged in the Southern District of Florida in an...more
The Biden’s Administration’s Fiscal Year 2023 Revenue Proposal includes “Modernize Rules” to address Digital Assets that will require reporting by certain Taxpayers of Foreign Digital Asset Accounts. ...more
The IRS and FBARs - On March 30, 2022, the IRS issued Publication 5569, Report of Foreign Bank & Financial Accounts (FBAR) Reference Guide. The 12-page publication provides helpful information to both taxpayers and tax...more
Special purpose vehicles (SPVs) are commonly employed in cross-border and structured finance transactions, as well as in asset finance transactions. In the context of asset finance transactions, SPVs can be a particularly...more
The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more
What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
Securitisation is a widely used method of raising debt finance on capital markets through the issue of asset-backed securities. Typically, income-producing assets are used as collateral backing for the issue of securities by...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Benjamin Franklin once famously wrote in a 1789 letter, “In this world nothing can be said to be certain, except death and taxes.” Many recognize the truth in Mr. Franklin’s statement. Some may also believe that certain death...more
Los Contribuyentes Estadounidenses con activos e ingresos financieros extranjeros no declarados corren el riesgo de que el Gobierno determine si su conducta fue intencional o no intencional. ...more
Streamlined Filing Compliance Procedures (Streamlined) is one of the options available for US Taxpayers with unreported foreign financial assets and income. ...more
With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more
Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated. Each of these has its own corresponding penalties and generally applies to United States...more
On October 16, 2018, the Organization for Economic Cooperation and Development (OECD) issued guidance to Financial Institutions (FIs) regarding what is known as “Golden Passports”. ...more
Intellectual Property (IP) assets play an increasingly significant role in corporate transactions — small and large — and the importance of involving IP counsel, particularly on the buyer’s deal team, cannot be overstated....more
On May 15, 2018, the United States District Court for the Western District of Texas issued an important ruling concerning the application of willful FBAR penalties under 31 U.S.C. § 5321. In United States v. Colliot, Case...more
On Friday, July 28, 2017, Treasury Secretary Mnuchin will preside over an executive session of the Financial Stability Oversight Council (Council) at the Treasury Department. The preliminary agenda includes a discussion about...more
A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more
El 12/29/2016, el Congreso de Colombia aprobó la "Ley 1819 de 2016". La nueva legislación es una reforma tributaria estructural encaminada principalmente a aumentar los ingresos para Colombia....more