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Dec 28, 2018

Deadline for Reporting Final Beneficiary to Brazilian Federal Revenue Ends on December 31

The below post is authored by our friends Ana Carolina Veloso Ferreira and Ana Paula Terra Caldeira at Azevedo Sette Advogados.

Are you a United States entity with significant capital or controlling interest in a Brazilian subsidiary? Year-end reporting requirements are fast approaching.» Read More

Jan 05, 2012

IRS Releases an Income Tax and FBAR Reporting Fact Sheet for U.S. Citizens and Dual Citizens Residing Outside of the U.S.

The IRS recently issued an important Fact Sheet (FS-2011-13) that applies to U.S. citizens and dual citizens residing outside of the U.S., many of whom are not aware that they are required to file U.S. income tax returns and, where applicable, the FBAR form (Form TD F 90.22-1,» Read More

Jan 03, 2012

Do You Own an Interest in a Foreign Account or own Securities in a Foreign Entity?

If so, you may need to file Form 8938, “Statement of Specified Foreign Financial Assets.” The IRS explains who needs to file in a new article, Do I Need to File Form 8938, “Statement of Specified Foreign Financial Assets”?

Certain U.S.

» Read More

Oct 14, 2010

Update: IRS Finalizes Schedule UTP which Affects Foreign Businesses

In April, we published “What Offshore Businesses & Tax Practitioners Need to Know About IRS Draft Schedule UTP,” a post on the Proposed Schedule UTP (Uncertain Tax Positions), which is a schedule certain foreign businesses would be required to file with their Form 1120 to disclose uncertain tax positions when the business assets are at least $10 million and the business issues or is included in audited financial statements.» Read More

Jun 22, 2010

Offshore Compliance Is Higher Under the HIRE Act

The Hiring Incentives to Restore Employment (HIRE) Act, enacted March 18, 2010, contains provisions attempting to promote job creation and stabilize the economy.  Here are some major provisions which may affect you and your business:

Foreign Account Tax Compliance: In the wake of UBS and the IRS Offshore Voluntary Disclosure Program, the HIRE Act rules have comprehensive measures to reduce offshore noncompliance with new tools which discourage perceived offshore tax abuse. » Read More