Yearly Archives: 2017

The IRS has posted its tables entitled Controlled Foreign Corporations, Tax Year 2012, which consists of two new tables presenting data from Form 5471, Controlled Foreign Corporations, and Form 8858, Information Return of U.S. Persons With Respect to Foreign Disregarded Entities,which are now available on SOI’s Tax Stats Webpage.

The tables present data from the estimated population of returns filed for Tax Year 2012.

• One table presents number, assets, and earnings for controlled foreign corporations and their foreign disregarded entities classified by selected country of incorporation. and
• The other table displays number, assets, and earnings for controlled foreign corporations and their foreign disregarded entities classified by selected NAICS industrial sector.

The OECD's Centre for Tax Policy launched a disclosure facility for reporting schemes that aim to circumvent the internationally agreed Common Reporting Standard (CRS) for automatic exchange of taxpayers' account information.

The disclosure facility, which can be accessed through the Automatic Exchange Portal, is part of a three step process the OECD has created to deal with schemes that purport to avoid reporting under the CRS. Under the three-step process 'all actual or perceived loopholes that are identified' will be analysed in to help the OECD deal with them.

The process, the OECD says, has a wide scope in terms of the financial institutions that are required to report, the financial information to be reported and the scope of account holders subject to reporting duties.

Jurisdictions subscribing to the CRS will also have to put in place anti-abuse rules to prevent any practices intended to circumvent CRS reporting and due diligence procedures.

The three step process to deal with CRS avoidance schemes complements the ongoing peer reviews carried out by the Global Forum on Tax Transparency and Exchange of Information for Tax Purposes to ensure the effective implementation of the CRS in all jurisdictions, says the OECD.

On 27 January 2017, 7 additional countries signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Countryby-Country (CbC) reports.  The signing took place at a ceremony held during the second meeting of the inclusive framework on BEPS on 26-27 January 2017.

1. Gabon,
2. Hungary,
3. Indonesia,
4. Lithuania,
5. Malta,
6. Mauritius and
7. the Russian Federation.

First automatic exchanges of information will start in 2017-2018 on 2016 information.

Have an International Tax Problem?  
 

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• The number of expatriates for 2016 is a 26% increase over 2015 and a 58% increase over 2014 (3,415).  

 On April 8, 2015, we posted Is it Time to Expatriate, where we discussed that the 2014 list of US expatriates’ shows an increase in the number of Americans who are renouncing their US citizenship or turning in their green card. We also discussed that the escalation of offshore penalties over the last 20 years is likely contributing to the increased incidence of expatriation.

The graph to the left is based solely on IRS data and shows the number of published expatriates per year since 1998.

The connection between the list of expatriates and the IRS implies a link to tax policy.

The U.S. is one of a very small number of countries that tax based on nationality, not residency, leaving Americans living abroad to face double taxation.

The escalation of offshore penalties over the last 20 years is likely contributing to the increased incidence of expatriation.

 Should I Stay or Should I Go?

Need Advise on Expatriation ... 

 

Contact the Tax Lawyers of
Marini & Associates, P.A.

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

Toll Free at 888-8TaxAid ((888) 882-9243)