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On December 13, 2016, final regulations were issued under Sections 6038A and 7701. The new rules treat a U.S. disregarded entity, wholly owned by a foreign person, as a “U.S. corporation” solely for the report on Form 5472 “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.”

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The Foreign Accounts Tax Compliance Act of 2010 (FATCA) requires foreign banks and other financial institutions automatically report the accounts held or controlled by U.S persons to the IRS on an annual basis. The goal of the automatic exchange of financial information in tax matters is increased offshore transparency, reduction of the tax gap and elimination of taxpayer noncompliance. The FATCA provisions are instituted trough:

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The IRS has officially started accepting 2016 tax returns for processing. More than 180 million tax returns will be processed this year, many of them prepared by tax practitioners. The practice of accountants and tax preparers is one of the most heavily regulated and ethical professions. Moreover, we firmly believe the vast majority of tax preparers are reputable, competent and trustworthy individuals. Despite the ethical and regulatory frameworks, there are tax preparers that do not follow even the core principles of the profession. Therefore, the Internal Revenue Service advises taxpayers to apply scrutiny and choose wisely. Based on the IRS recommendations and our perception of good business practices, we have selected the top 10 tips on choosing a legitimate tax professional.

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The Protecting Americans from Tax Hikes (PATH) Act of 2015, made major changes to tax and information return filing dates. The rationale behind the accelerated return due dates is streamlining the tax return filing information and strenghtening the IRS identity theft prevention and detection efforts. Most of the changes are effective for tax and information returns due in 2017. How the new return due dates affect you and your business?

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The last several years marked a tremendous increase in the number of Foreign Bank Account Reports filed with the Treasury Department's Financial Crimes Enforcement Network. In fact, the IRS has announced that the number of Forms 114 (Former TD.F. 90.22-1 or FBAR) filed in 2015 topped at over 1.1 million! This record number shows an upsurge in awareness of the foreign financial account reporting requirements and a trend towards voluntary compliance. Still, many taxpayers experience practical difficulties in complying with the FBAR regulations. So, what it takes to do it right?

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The Individual Taxpayer Identification Number (ITIN) is a nine-digit number that is used to identify certain individual taxpayers within the tax system. The ITIN is assigned directly by the IRS to eligible nonresident and resident taxpayers who do not have and do not qualify for a Social Security Number. The first ITIN was issued back in 1996 when the IRS replaced the temporary Internal Revenue Service Number (IRSN) with the ITIN as a mean to address accurate identification of international taxpayers with tax return filing or reporting requirements. Until recently, the number was personal and valid for life. Well, not anymore!

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The Streamlined Foreign Offshore Procedure (SFOP) was developed by the IRS to address noncompliance with the foreign financial assets reporting requirements, an omission of a foreign-source income or a failure to file certain information returns. The streamlined procedure is available to US citizens, expatriates and residents whose noncompliance with the internal revenue laws was not borne by a willful conduct or an attempt to avoid paying taxes in the United States. If you have resided outside the United States and you failed to file returns or under-reported foreign-source income, the SFOP is the shortest way to regain compliance without the burden of severe penalties. So what is the fuss about it?

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This tax guide aims to supplement and enhance your understanding of the UK income tax laws by providing current insights and practical information. In addition, we have also stressed on valuable tax planning opportunities and tax treaty provisions available to United States citizens, permanent residents, and expatriates residing in the UK.

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