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Yearly Archives: 2013

Foreign Trusts With Individual Trustees Are NFFE's & Are Not Subject to FATCA Reporting.

February 7, 2013

As we reported on Monday, January 28, 2013 in our post Significant Changes in Final FATCA Regulations, the US Treasury Department published final rules governing enforcement of the Foreign Account Tax Compliance Act (FATCA).

The regulations indicate that trusts with individual trustees will be NFFEs (non financial foreign entities), whether those individuals are professional trustees are not. This is good as such trusts would be excluded from the FATCA registration requirements.

However trusts where there is a corporate trustee, will be considered to be financial institutions (FIs) and may have to register as an Investment Company.

This means that foreign trusts with corporate trustees are potentially subject to the FATCA withholding rules and they need to register as an Investment Company and provide the required information in order to avoid FATCA withholding tax obligations.

Stay tuned and FACTA and its associated Regulations continue to develop and unfold! 

Are you a US Person with UNREPORTED INCOME from a Foreign Bank Account???
Are you a Foreign Trust with FATCA Problems???

 
 
 
Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at:www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243). 
 

Read more at: Tax Times blog

Advantages of Using an Offer in Compromise to Settle Payroll Taxes

February 5, 2013


 Very few tax professionals and business owners realize, that just like a personal IRS tax debt, back payroll taxes can be negotiated down using the IRS Offer in Compromise program. 

Anthony E. Parent, Esq. posted a good article which discuss the six advantages of using an Offer in Compromise to settle back payroll tax debt, which include:

1. A More favorable repayment schedule.

2. You can direct payments to the Trust Fund Penalty Taxes.

3. You can avoid paying the Trust Fund Penalty personally.

4. The Offer in Compromise is NOT Considered by your Revenue Officer.

5. No interest on repayment.

6. Collection hold in place.
 
Have Payroll Tax Problems?  Need and Offer in Compromise? 

Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at: www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

 

Read more at: Tax Times blog

Study Shows that US Corporations are increasing the use of Tax Havens to Shift Profits.

February 4, 2013

A US government investigation has confirmed that American multinational companies are increasingly adopting tax strategies to shift their profits out of high-tax jurisdictions such as Canada and the UK.
The Congressional Research Service analyzed profit data from multinational companies and compared reported profits and other business activity in lower-tax jurisdictions versus higher-tax countries like the United Kingdom and Canada.

In the tax year 2008, they declared 43 percent of their overseas profits in Bermuda, Ireland, Luxembourg, the Netherlands, and Switzerland, while placing only 7 per cent of their foreign investments in those countries.
What to Reduce Your Tax Burden?

Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at: www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

Source:

Reuters

 

Read more at: Tax Times blog

US Tax Court Finds Taxpayer Liable For Transferee Liability

February 1, 2013

U.S. Tax Court held in T.C. Memo. 2013-32 that the taxpayer George Schussel, was subject to transferee liability, because he caused his corporation to evade income taxes, the Jan. 31

Schussel v.Commissioner , T.C., No. 4050-11, T.C. Memo. 2013-32, 1/31/13
Don't Be Subject to Transferree Liability...


Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

 

 

Read more at: Tax Times blog

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