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Yearly Archives: 2016

IRS Removes QI, WP, and WT Questions from the FATCA Online Registration System

Soon, the IRS will launch a new

  1. Qualified Intermediary (QI),
  2. Withholding Foreign Partnership (WP) and
  3. Withholding Foreign Trust (WT) system

allowing these entities to manage their information online. The QI, WP and WT related questions will be available in the new system.

Additional information on the updates to the FATCA Online Registration System is available via the FATCA Online Registration user guide.

Have a Tax Problem? 
 
 
 
Contact the Tax Lawyers at
Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).

Read more at: Tax Times blog

Foreign Owned Domestic Disregarded Entities Must Report Under New Regs.

On April 15, 2016 we posted US Pressured For Beneficial Ownership Rules where we discussed that in a speech by Treasury deputy assistant secretary Jennifer Fowler to a financial crime conference earlier in April noted that the Treasury is in the process of introducing a new rule forcing financial institutions to perform customer due diligence checks on new clients.

This rule, first published in August 2014, is still under consultation, though close to being finalized. We also discussed that the regulations are likely in response to the growing view of the United States as a tax haven for foreigners seeking to evade their foreign tax obligations or otherwise conceal their holdings.
The Treasury Department noted in its March 30th statement that one purpose of the new regulations will be to assist foreign countries in obtaining information regarding their own taxpayers under the United States' tax treaties and tax information exchange agreements. 

The new regulations where to be issued under section 6038A of the Internal Revenue Code, which requires certain foreign owned U.S. corporations to file a Form 5472 disclosing the identity of their foreign owners and reporting certain related-party transactions. The filing requirement generally applies where more than 25% of the voting power or value of all classes of stock are owned by a single foreign owner. 

The IRS has now issued these regulations as final on 12/12/2016a nd they treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner, but only for the reporting, record maintenance and associated compliance requirements that apply to 25% foreign-owned domestic corporations under Code Sec. 6038A.
 
These changes are intended to provide IRS with improved access to information that it needs to satisfy its obligations under U.S. tax treaties, tax information exchange agreements and similar international agreements, as well as to strengthen the enforcement of U.S. tax laws. TD 9796, 12/12/2016; Reg. § 1.6038A-1, Reg. § 1.6038A-2, Reg. § 301.7701-2. These regulations are effective December 13, 2016.

 Have a Tax Problem?
 
 
Contact the Tax Lawyers at
Marini & Associates, P.A.
 
 for a FREE Tax Consultation Contact US at 
or Toll Free at 888-8TaxAid (888 882-9243).
 

Read more at: Tax Times blog

Trump's Anti-Union Drumbeat Could Be Trouble for the IRS


We previously posted President-Elect Donald Trump Is Less Than Ideal for Tax Advisers? where we discussed that Donald Trump has proposed tax reforms that would:
 
  1. Significantly reduce marginal tax rates for both individuals and businesses,
  2. Increase standard deduction amounts to nearly four times current levels,
  3. Limit or repeal some tax expenditures,
  4. Repeal the individual and corporate alternative minimum taxes 
  5. Repeal the estate and gift taxes, and
  6. Tax the profits of foreign subsidiaries of US companies in the year they are earned.


All of which may not be good for tax advisors.

Now according to Bloomberg BNAIRS employees could be in for a rocky ride if President-elect Donald Trump and Congress move forward with sweeping pledges to rein in federal employee benefits and cripple unions.

 

Trump has vowed to place a hiring freeze on federal jobs and shrink the workforce, as one of his first efforts once in office, and ease firing restrictions. Other ideas Republican lawmakers have floated could also come to fruition now that no veto threat looms, such as ending automatic pay raises and changing benefits plans.

Those moves would be jarring for employees across federal agencies, but would particularly sting at the Internal Revenue Service, an agency that has lost millions of dollars through budget cuts and thousands of employees through attrition and retirement.

 Have a Tax Problem? 
 
 
 
Contact the Tax Lawyers at
Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).

 

Read more at: Tax Times blog

IRS Revises List of Qualifying Countries for Automatic Exchange of Information

In a Rev Proc 2016-56,2016-51 IRB, the IRS has updated two lists of countries with which the U.S. has in effect an agreement that requires payors to report certain deposit interest paid to nonresident alien individuals who are residents of the other country under Reg. § 1.6049-8(a) and Reg. § 1.6049-4(b)(5).
 
One list is of countries with which the U.S. has in effect an income tax or other treaty or a bilateral agreement and the other is of countries with which IRS has determined that an automatic exchange of information is appropriate. 

The following are the countries with which the United States has in effect an income tax or other convention or bilateral agreement relating to the exchange of tax information within the meaning of section 6103(k)(4) pursuant to which the United States agrees to provide, as well as receive, information and under which the competent authority is the Secretary of the Treasury or his delegate:

  1. Antigua & Barbuda
  2. Aruba
  3. Australia
  4. Austria
  5. Azerbaijan
  6. Bangladesh
  7. Barbados
  8. Belgium
  9. Bermuda
  10. Brazil
  11. British Virgin Islands
  12. Bulgaria
  13. Canada
  14. Cayman Islands
  15. China
  16. Colombia
  17. Costa Rica
  18. Croatia
  19. Curacao
  20. Cyprus
  21. Czech Republic
  22. Denmark
  23. Dominica
  24. Dominican Republic
  25. Egypt
  26. Estonia
  27. Finland
  28. France
  29. Germany
  30. Gibraltar
  31. Greece
  32. Grenada
  33. Guernsey
  34. Guyana
  35. Honduras
  36. Hong Kong
  37. Hungary
  38. Iceland
  39. India
  40. Indonesia
  41. Ireland
  42. Isle of Man
  43. Israel
  44. Jamaica
  45. Jersey
  46. Korea, Republic of
  47. Latvia
  48. Liechtenstein
  49. Lithuania
  50. Luxembourg
  51. Malta
  52. Mauritius
  53. Mexico
  54. Netherlands
  55. New Zealand
  56. Norway
  57. Poland
  58. Saint Lucia 
  59. Slovak Republic
  60. Slovenia
  61. South Africa
  62. Spain
  63. Sweden
  64. United Kingdom

 
 Do You Have Undeclared Income 
From A Foreign Bank
Organized in 1 of These Countries?
 

 

 
 Want to Know if the OVDP Program is Right for You?

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

 

 

 

 

 

 

 

Read more at: Tax Times blog

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