Entity Classification of foreign companies and trusts in the US and penalties associated with getting it wrong!

In our experience the area that carries the most risk is the failure of a taxpayer to properly classify an Australian entity under US law....

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Penalties for non-disclosure of foreign financial assets

The FBAR, together with the FATCA regime, requires U.S. taxpayers to disclose foreign financial assets subject to certain threshold requirements. Due to the cross boarder...

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Streamlined Offshore Procedures vs amended and delinquent filing

The IRS has announced that it will close the 2014 OVDP effective September 28, 2018. For taxpayers that have failed to disclose foreign financial assets...

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OVDP to end – If you have intentionally been non compliant with US taxes the time to act is now!

In the publication featuring the Tax Specialist in February 2017 titled “Nowhere to Hide – An Update on Remediation Options for U.S. Taxpayers with Australian...

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The Multilateral Instrument and The Changing Framework of Permanent Establishment

On November 2016 over 100 jurisdictions concluded negotiations on the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting....

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Wine, Wine, I need more Wine: While Trump’s Tax Reform is Delivering on The Election Promises Made to his Base, the Tax Reform has a Biting Impact on Foreign Businesses!

In my Whitepaper “United States Entity Considerations in the Trump Era”I discussed the opportunities that will exist for companies that wish to headquarter themselves in...

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Global innovators are paying for Trumps Tax Reform? Have you received the invoice for your share?

In the Whitepaper “United States Entity Considerations in the Trump Era” we discussed headline tax reform but we did not discuss the deep issues, like...

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The US will not be my 1st Choice as a holding company jurisdiction, will it be yours?

In a whitepaper, that I had published in the Tax Specialist in April of 2018, I made the bold assertion that people may start looking...

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What is a check the box election and should a foreign corporation make one?

In our whitepaper, “United States entity considerations in the trump era” we outlined how the check the box regime can impact Australian businesses. While that...

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I have an online business selling products to US customers – am I required to pay tax in the US?

In our US Market Entry Guide we talked about the timing and drivers for establishing an entity in the US. We are often asked by...

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