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Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

In FBAR, International Tax by Jason FreemanLeave a Comment

A recent FBAR case held that non-willful failures to report foreign bank accounts can give rise to a $10,000 penalty per account—per year.  In United States v. Boyd, a federal district court upheld the IRS’s assessment of multiple penalties for non-willful failures to file a FBAR.  A $10,000 penalty per account creates substantial exposure for taxpayers with multiple unreported accounts. …

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International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

In International Tax by Jason FreemanLeave a Comment

Leaders from the Joint Chiefs of Global Tax Enforcement recently issued a notice, available here, commemorating the one-year anniversary of the formation of the so-called J5 Group.  The Joint Chiefs of Global Tax Enforcement have combined forces across the globe in an effort to target international tax evasion, hidden bank accounts, and money laundering.  The J5 intends to usher in …

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Advising International Business Ventures: “Tested Income” under GILTI

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures.  International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post provides a short introduction to the …

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U.S. Shareholder: Changes Under the TCJA

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post provides a short introduction to the …

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Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a second …

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Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Tax Reform’s New GILTI Tax

In GILTI, International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Passive Foreign Investment Companies (PFICs)

In International Tax, PFIC by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  This post focuses on, and provides a short introduction to, the Passive Foreign Investment Company (“PFIC”) rules.   U.S. taxpayers investing in foreign corporations may …

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Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

In CFC, International Tax by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometime unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  This post focuses on, and provides a short introduction to, the Controlled Foreign Corporation (“CFC”) rules under Subpart F of the Code.   Historically, U.S. …