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J5 Continues its Efforts to Identity International Tax Cheats

In Fraud, International Tax, Offshore Tax by Matthew RobertsLeave a Comment

The Joint Chiefs of Global Tax Enforcement (known as the “J5”) has been busy the last few months.  The group – compromised of tax department heads from Australia, England, Canada, the Netherlands, and the United States – was formed in June 2018 to facilitate the sharing of information regarding international tax cheats.  A summary of some of their more recent …

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New Changes Are Coming to Partnership Withholding

In International Tax, Offshore Tax, Partnership Tax, Tax Reform by freemanlawdevLeave a Comment

Section 13501 of the Tax Cuts and Jobs Act created a withholding requirement on the transfer of non-publicly traded partnership interests[1] by amending §§864(c) and 1446 of the Internal Revenue Code.[2]   Section 864(c)(8) provides that gain or loss from the sale, exchange, or other disposition of a partnership interest by a nonresident alien or foreign corporation is effectively connected with …

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20/22 Vision – Tax Consequences for Puerto Rico

In International Tax, Offshore Tax by freemanlawdev1 Comment

In 2012, Puerto Rico enacted two pieces of legislation to encourage and attract an infusion of foreign capital—Act 20 and Act 22. These two acts provide tax incentives for both individuals and businesses depending on their circumstances. Taxpayers looking for tax-saving opportunities should consider the benefits of these two acts, especially in relation to the U.S. tax system and recent …

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The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

In FATCA, FBAR, Offshore Tax, OVDP by Jason Freeman and Spencer BanksLeave a Comment

The Paradise Papers represent the latest large-scale leak of financial documents believed to link thousands of companies and individuals to hidden offshore accounts and secret tax havens.  The leak was massive, totaling some 1,400GB of data—that translates to an estimated 13.4 million documents covering a period from 1950 to 2016.[i]Nearly half of the leaked documents come from corporate registries in …

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Foreign-owned domestic disregarded entities: The new reporting requirements

In International Tax, IRS Regulations, Offshore Tax by Jason B. FreemanLeave a Comment

Domestic disregarded entities wholly owned by foreign persons are now subject to new reporting obligations. The Treasury Department and the IRS recently issued final regulations (T.D. 9796) that treat such entities as domestic corporations rather than as disregarded entities for purposes of the reporting requirements under Sec. 6038A. The regulations are effective for tax years beginning on or after Jan. …