US Taxpayers given some Reporting Relief on certain Foreign Trust Investments

Jurate Gulbinas   |   10 Mar 2020   |   2 min read

Section 6048 requires US taxpayers to make an annual report regarding financial or asset transfers in relation to the receipt of distributions from foreign trusts. Taxpayers can be penalised if they fail to comply. Unfortunately many taxpayers have been caught out when it comes to reporting foreign retirement investments and other trusts. 

On March 2nd 2020 the IRS released Rev. Proc. 202-17. This change comes into effect on March 16 and provides taxpayers with certain foreign investments with an exemption from section 6048 reporting requirements on those investments. Accordingly, eligible US citizens with some tax favored foreign retirement investments and other trusts, have less duties in their reporting requirements. Furthermore, eligible individuals can now apply for a refund of any penalties that they have incurred as a result of section 6048 reporting requirements with their applicable tax-favored foreign trusts. 

The reason behind the change is that there are already a number of restrictions imposed by the countries where those trusts are located and there are already additional reporting requirements in the US under section 6038D regarding interests in these trusts. This alleviates the pressure of being penalized for meeting the section 6048 reporting requirements and reverses the penalties previously imposed in such cases. 

Once the change comes into place it will apply to any prior tax year that is still open. 

One of the reasons this relief is important is because it covers a requirement that many taxpayers and tax professionals haven’t realized was in place. This is because people tended to assume that the tax and reporting requirements were deferred until the point of retirement and they didn’t understand which international information reporting forms were to be used. Alleviating this reporting requirement will help reduce a lot of confusion in the field. 

If you have a foreign retirement or trust investment that may qualify you should look into Rev. Proc. 2020-17 or seek further advice for your specific situation. 

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Making a check-the-box election as a foreign corporation

Jurate Gulbinas   |   4 Mar 2020   |   4 min read

This article relates to foreign business founders with an active business, who are moving to the US. There is a risk that foreign earnings may be double taxed when your organisation is taxed as a US entity. This is due to the application of US attribution rules (Controlled Foreign Corporation (CFC) rules) and Passive Foreign Investment Company (PFIC) rules.

To avoid being double taxed and ensure that foreign tax credits can be appropriately applied, it may be advisable to make a check-the-box election. This election essentially means that foreign corporations are choosing to elect their US tax status at the point in time that the US tax system becomes ‘relevant’ to them.

This check-the-box system is a tax regime that doesn’t just impact organisations that are set up in the US. It can also impact Australian businesses and global businesses when the foreign founder of the corporation moves to the US.

When does the US tax system become ‘relevant’ to a foreign corporation:

The US tax system is considered to be ‘relevant’ to a foreign corporation when one of the following applies:

a) the foreign corporation derives US sourced income;

b) the foreign corporation is required to file an income tax return in the US; or

c) the owner of a foreign corporation becomes a US tax resident (ie a US Person).

Why might a check-the-box election be made?

The most basic reason for making the check-the-box election is to ensure that the owner of the corporation in the US is properly credited with the foreign tax payments. A check-the-box election will avoid the attribution of income under CFC rules or the loss of long term capital gains tax rate discounts when shares are transferred in a passive foreign investment company (PFIC).

When will a foreign corporation be a CFC?

When US shareholders own more than 50% of the shares, either directly or indirectly, then the foreign corporation will be considered to be a controlled foreign corporation (CFC). To be considered a ‘US shareholder’ the person must own more than 10% of the voting rights or stock value of the foreign company.

When is a foreign corporation a PFIC?

A passive foreign investment company (PFIC) exists when one of the following two conditions are satisfied:

  1. Passive investments generate at least 75% of a corporation’s gross income (as opposed to regular business activities); or
  2. At least 50% of the corporation’s assets create passive income. Passive income includes interest, dividends and capital gains.

What is a foreign eligible entity?

A foreign eligible entity is defined by whether a member has limited liability or not. This is a default classification under the check-the-box regulations. When all members of the corporation have limited liability the US taxes the foreign eligible entity as a corporation. When at least one member does not have limited liability the entity is not a foreign eligible entity.

An eligible entity may make a check-the-box election to opt out of the default classifications.

Warning on making an election after default classification has been made

It is important to make your election prior to the default classification being applied. This is because making a later election will change the organisation’s classification. Such a change in classification can trigger a liquidation event.

When you should make a check-the-box election:

To ensure the check-the-box election is made appropriately you should consider making the election when you meet all of the following conditions:

  1. you own a foreign corporation
  2. the US tax system is relevant for your corporation
  3. you need to apply foreign tax credits against your US corporate tax regime
  4. you wish to avoid applying the CFC or PFIC rules.

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Online Business with No Physical Presence May Be Liable for US Sales Tax

Jurate Gulbinas   |   29 Nov 2019   |   4 min read

In our previous article on the topic of sales tax in September 2018, titled “Understanding Sales Tax in the US” Click here to read the post, we discussed the ways in which US states themselves have taxing powers over sales where there is a sales tax nexus. The sales tax nexus is where your business has a substantial enough presence in a state for the state authorities to deem that you are taxable in such state. Now, however, companies that engage in online sales may be subject to tax obligations regardless of their sales tax nexus under the recent Supreme Court case, South Dakota v. Wayfair.

What happened in South Dakota v. Wayfair?

In South Dakota v. Wayfair, the state of South Dakota was suing Wayfair, an online retailer, for their failure to withhold and remit taxes on online sales inthe state.Wayfair argued against having to do so because under a prior Supreme Court decision, states could only apply sales tax on sellers with a sales tax nexus, which required some sort of physical presence. The Supreme Court decided it was time to take a hard look at this precedent as the growth of online retailers skyrocketed. In doing so, the Court held that states can now require online retailers to collect sales tax if certain revenue or quantity thresholds are met, regardless of whether they have a physical presence in the state.

What are the effects of South Dakota v. Wayfair?

Now, your business will need to withhold sales tax where the business:

  1. Has a sales tax nexus with the state; or
  2. Engages in online sales that meet the threshold level for the state (“Economic Nexus”).

This ruling primarily affects businesses with large eCommerce sales, Software as a Service sales, and digital goods/services sales. Additionally, for foreign companies who transact business in the US, this ruling may affect you even if you do not have a US permanent establishment.

What is the applicable state “threshold” for online sales?

A business will only need to comply with the ruling of South Dakota v. Wayfair if it reaches the particular state’s gross revenue or quantitative transaction threshold. The most popular gross revenue threshold utilized by states is $100,000 or more in in-state sales; whereas, the most popular state threshold based on the number of transactions is 200 in-state sales. It is critical that for each state you transact business in, you review their specific threshold requirements to ensure compliance.

I think my business meets the online sales threshold of a state, what next?

If your business has meets the online threshold of a particular state pursuant to the sales tax rules of such state, you will be required to register for a state sales tax permit and collect sales tax from all buyers in that state. The sales tax permit is obtained from the relevant state tax department.It is imperative that your business file sales tax in all jurisdictions where your business meets the threshold.

Upon receiving the sales tax permit you will be assigned a sales tax filing ‘frequency’ requiring sales tax filing to be made monthly, quarterly or annually. Again, each state has its own requirements and criteria in determining the filing frequency.

It is important to note that the process of determining whether your business is subject to the state sales tax and therefore is required to register for a sales tax permit, is of particular importance as failing to obtain a sales tax permit is deemed as criminal fraud.

How can CST help you?

Navigating through the sales tax rules can become an overwhelming process when trying to focus on the growth of your business in a new market. If you need assistance in analyzing whether your business has a sales tax nexus (physical and/or economical) in a state and whether you are required to be sales tax compliant, please don’t hesitate to get in contact with a member of our team.

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Tax Accountant/ International Tax Advisor

Jurate Gulbinas   |   8 Aug 2019   |   2 min read

About CST Tax Advisors

CST Tax Advisors is a global firm of CPAs, chartered accountants, and attorneys that advise globally mobile private clients, family offices, and established privately owned companies on market entry. CST believes in a ‘tax without borders’ approach to integrating global private clients solutions. CST has offices in 3 countries that are connected daily to deliver integrated solutions.

Responsibilities

  • Under direct supervision of a licensed Certified Public Accountant (CPA), review and analyze financials to prepare federal and state income taxes, sales and use, extensions, and estimated tax for corporations, partnerships, and individuals, focusing on expats and international clients of high net worth
  • Prepare documents, records, and financials to ensure proper international tax compliance under US tax laws and different tax treaties and reporting requirements for state/federal tax law
  • Evaluate, design, implement, and review tax process procedures to support adequate data input and analysis as well as accurate tax planning, advice and consulting to clients
  • Interpret and analyze various tax legislation (i.e. proposed tax regulations and Tax Cuts and Jobs Act of 2017) impacting U.S. residents, expats, and foreigners and provide recommendations on compliance
  • Conduct tax research on tax controversy for pre-immigration consulting and managing director’s assignments through CCH and Bloomberg Tax and provide specialized advice and counsel on domestic and foreign taxes

Minimum Requirement

  • Bachelor’s Degree in Accounting, Finance, Taxation, or similarly related field.
  • Master of Taxation preferred

Compensation

Competitive

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FAQ

Jurate Gulbinas   |   14 Jun 2019   |   14 min read

What is a CFC?

A CFC is a foreign corporation in which more than 50% of the shares are held by US Shareholders. US Shareholders are shareholders in a foreign corporation that own more than 10% of the total voting or value of shares on issue in such foreign corporation.

What is a PFIC?

A PFIC is a passive foreign investment company. A passive foreign investment company is a company that derives at least 75% of its gross income from passive sources that are not regular business activities, or at least 50% of the company’s assets produce income that is passive.

What is a grantor trust?

A grantor trust is a trust (whether domestic or foreign) of which the grantor is considered the owner of the trust assets income and losses for US tax purposes. In the context of a foreign trust any income, gains or losses that are derived by the trust are attributed to the grantor and taxable to them in the US regardless of who they are distributed to under the laws of the foreign country.

What is GILTI?

Global Intangible Low Tax Income is income that is derived by a controlled foreign corporation that is not Subpart F income that is taxed at a rate of not more than 95% of the US Corporate Tax rate of 21%.

What is BEPs?

BEPS means Base Erosion and Profit Shifting. The G20 BEPS initiative was implemented to allow the global community to fight large scale tax avoidance through profit shifting.

What is transfer pricing?

Transfer pricing is the price at which divisions of related party companies transact with one another.

What are the check the box regulations?

The check-the-box regulations establish how a foreign or domestic entity should be taxed in the US (i.e. as a disregarded entity, a partnership or a corporation). All entities have a default status. If an entity is an ‘eligible entity’ that can also choose to an alternate tax status.

Is superannuation taxable in the US?

i. The US Australia Income Tax Treaty predates the introduction of the Superannuation Guarantee in Australia.

ii. It was designed to deal with the old form of defined benefit plan that had one taxing point, which was on distribution not the three taxing point system that exists today. If you compare the US Australia Income Tax Treaty with the US UK Income Tax Treaty you can clearly see the gaps.

iii. To the extent that the treaty is silent to the manner in which a type of income should be taxed it will be taxed under domestic law.

iv. The two sections of the International Revenue Code of 1986 that can tax Australian superannuation are sections 409A or 402(b) IRC. To say there is a one size fits all model when it comes to the US taxation of Australian super is a bit like saying that Russia did try and influence the US election. In case it is not clear I am saying that there simply is not one model that suits all circumstances and the reason for that is set out below.

v. Section 409A governs non qualified deferred compensation plans and 402(b) governs non exempt employee trusts.

vi. If you apply section 409A to your super you treat it as social security and you exempt it from US taxation under Article 18(2) of the US Australia Income Tax Treaty. You have found a big red bow and tied it around this issue. You are wining.

vii. However, here is the rub. In order to classify your super as social security you need to have the protection of the US Australia totalization agreement and this agreement only cover contributions that are mandatory contributions that have been made by employers on behalf of their employees under the superannuation guarantee system.

viii. I can understand the rationale for that. The guarantee does bear some similarity to social security. However, for most Australians their superannuation is more complex than that. Most employees have in addition to the guarantee amounts, made further taxed and non taxed contributions to their accounts.

ix. Furthermore, many other Australians that do not hold their superannuation in a retail accounts are owners of self managed superannuation funds. When you look at legislation and verbiage of section 409A it feels like it should have application to a retail superannuation account and not a self managed superannuation fund and the legislation and verbiage of 402(b), feels like it would have application to a self managed superannuation fund and not a retail account.

x. The big issue here is that if a superannuation benefit is not protected by the Treaty under Article 18(2) or Article 18(1) you need to apply the domestic law that is applicable to your circumstances and just because section 409A has some application to your circumstances does not mean you should not consider or apply section 402(b) to your circumstances. This applies for both retail or self managed superannuation funds.

xi. You need to be mindful of the position you are taking and the risks associated with getting it wrong.

xii. If your benefits are taxed under section 402(b) rather than 409A the taxation and information reporting consequences are dramatically different. One is not taxed and the other is taxed as ordinary income. If you are reporting your benefits under section 409A you do not have an obligation to report your benefits on a Fincen 114 (Fbar) or 8938 whereas if your benefits are taxable under section 402(b) you do have an obligation to report the benefits on those forms.

xiii. These forms carry substantially penalties if they are completed incorrectly or they not completed at all and should be.

xiv. Whenever I see one outcome that is all gravy and another that all hellfire I step back and ask myself what is the catch.

xv. When it comes to super there is no silver bullet. You need to understand the issues and apply them to your circumstances in way that suits your tolerance for risk.

How do double tax agreements work?

Double Tax Agreements are conventions signed between 2 countries that override domestic law to ensure that an individual or entity formed in a particular country is not taxed twice on the same income.

What is a permanent establishment and why should I know about it?

A permanent establishment is the cornerstone of business taxation as determined by double tax agreements. If a business that is resident of a particular country with which the US has a double tax agreement does not have a permanent establishment in the US, it cannot have a liability for federal taxation in the US.

How does state income tax work?

In the US, state income tax laws are administered and levied separate to the Federal tax laws enforced by the Internal Revenue Service (IRS). Each state applies their own tax system when can often create confusion and complexities for both individuals and businesses alike as the state tax rules can vary widely.

For companies doing business in the US, you can create a state corporate income tax liability where you have triggered a sufficient connection or “nexus” with a state. The state income tax is generally based on the business income of the corporation attributable to activities and revenue generated from activities within such state. Again, each state has different rules on what will amount to a taxable nexus. Some examples of nexus include attending trade shows, warehousing, having staff resident in a particular state or where the business server is located.

More recently we have seen a spike in queries regarding whether a state income tax nexus has been created by selling products on Amazon FBA. Products are often warehoused in states before being sent to the purchaser. This can create a state income tax nexus for sellers on Amazon FBA which may require state income tax and other registrations to be made.

Anyone doing business across more than one state should ensure that they have an understanding of their state tax requirements to ensure they are compliant with state business and tax requirements.

How does state sales tax work?

Much like state income tax, sales tax is governed by each individual state and is separate to the federal tax system. The result of this is that anyone doing business in the US can often find themselves trying to navigate through the sales tax rules of each state. This can get clear as mud.

You are required to collect sales tax from customers or buyers in any state in which you have a sales tax nexus. A sales tax nexus is created when you have a certain level of connection to the state. The criteria for creating a sales tax nexus is different in every state, however having a physical presence in a state will most likely create a nexus. In certain states, making sales exceeding a certain revenue amount or making a certain number of transactions in a state can create a nexus. If you have a sales tax nexus, you are required to register for a sales tax permit in that state.

The sales tax rate you are to collect will vary on whether you are based in an origin-based sales tax state, or whether you have created a sales tax nexus in a destination-based sales tax state. If you are based in an origin-based sales tax state, generally you charge the sales tax rate of the state in which you are located on all sales. If you have a sales tax nexus in a destination-based sales tax state, you collect sales tax based on the where the buyer is located.

What are the tax consequences of arriving in USA and becoming tax resident?

The consequence of becoming a U.S. Person (a U.S. tax resident) is that you are taxed on your worldwide income. That is income and gains sourced anywhere in the world are taxable in the U.S., subject to reduction by foreign tax credits or exclusions.

What is the minimum time I can remain in USA without being tax resident?

The U.S. is one of only two countries in the world to tax extraterritorially, that is to tax its citizens and permanent residents (Green Card holders) on their worldwide income regardless of how much time they spend in the country. So if you are a citizen or you hold a Green Card you are taxable on your worldwide income even if you spend 0 days within the U.S. in a calendar year. If however, you reside in the U.S. on a non-immigrant visa, you need to apply the Substantial Presence Test to your circumstances.

The Substantial Presence Test determines if you are physically present in the US at least 31 day during the current year and 183 days during the 3-year period that includes the current year and the previous two years by applying the following formula:

Days in U.S. in current year x 1 (Year 1) + Days in U.S. in year immediately preceding current year x 1/3 (Year 2) + Days in U.S. in year preceding the Year 2 (Year 3) x 1/6;

If you exceed the minimum 183-days under this formula, then you will be a resident for purposes of U.S. tax law.

Students, teachers and trainees are exempt from substantial presence test. Please contact our office regarding more details.

Does USA tax its residents on a world wide or territorial basis?

The U.S. taxes on a worldwide and extraterritorial basis.

Is foreign income taxable in USA e.g. foreign rental income, foreign interest income and foreign dividend income?

Yes, foreign sourced income is taxable in the U.S., subject to reduction by foreign tax credits and exclusions.

Does USA tax on a remittance basis?

No, the U.S. does not have a remittance basis of taxation.

Does USA have a sales tax or VAT tax on purchases?

Yes, the U.S. does have a sales tax on the sale of goods. Sales tax rate is determined by the state and local governments and thus varies from 5.5% to 9.45%. California state sales tax rate is 8.41%. Few states do not have sales tax.

Does USA have a capital gains tax that taxes me when I sell foreign assets?

Yes, the U.S. taxes its residents on gains realized on the sale of foreign assets.

Does USA have an estate tax or death tax?

Yes, the U.S. has an estate tax.

What is the top tax rate in USA?

Currently highest federal tax rate is 39.6%. The highest state rate of tax in California is 12.3% and 8.82% in New York.

Does the tax rate vary for different types of income and if so what are the rates?

Yes, long term capital gains (gains realized upon the sale of an asset that has been owned for 12 months or more) are taxed at the rate of 20%, as are qualified dividends. All other forms of income are taxed at full tax rates.

What are the common tax deductions available in USA?

Passive property losses (negative gearing) are deductible if you earn less than $100,000. If you earn between $100,000 and $150,000 the losses are partially deductible. If you earn more than $150,000 the losses are not deductible currently but may be carried forward and offset against future passive income or capital gains. Contributions to qualifying pension plans are deductible provided they do not exceed statutory limits. Home mortgage interest on up to $1M of debt for your principal residence is deductible as is property tax. Contributions to Health Services Accounts are deductible.

Does USA require joint tax returns to be filed for me and my spouse or are separate tax returns required?

Married taxpayers usually file married joint tax returns. Married separate tax returns may be filed as well.

If I have a foreign company or foreign trust before I arrived in USA is the income of that company or trust taxable?

If the trust is a grantor trust or the company is a controlled foreign company and the income it derives is Subpart F income, the income will be taxable in the U.S., even it is earned in another country. Most European and English common law trusts are grantor trusts.

Do children under 18 pay a higher rate of tax on certain types of income?

Yes, there is a so called “Kiddie” tax in the U.S.

Is there a gift tax in USA?

Yes, there is a gift tax in the U.S. 2014 annual exclusion gift amount is $14,000.

What are the personal tax exemptions in USA e.g. a gift from an overseas relative or a foreign insurance payout?

Most earned and passive investment income in taxable in US, however there are types of receipts that are excluded from taxable income. Examples are life insurance proceeds received by the qualified beneficiary, tax-exempt interest, property acquired by bequest, devise, or inheritance.

If I receive shares as part of my salary is this taxed in USA?

Yes, compensation received via the issuance of shares is taxable (in the year of the grant or later, depending on type of the grant) in the U.S.

When I leave the country is a ‘termination payment’ taxed by USA before I leave?

Yes, if a termination payment is received in consequence of the termination of employment in the U.S., the income derived will be sourced to the U.S. and taxable in the U.S.

What are other tax consequences of leaving the country?

Since the United States taxes its citizens and residents on their worldwide income, the only way to avoid paying U.S. tax is to expatriate or terminate residency.
If you are a “covered expatriate”, you might be subject to income tax on the net unrealized gain as if all property that you had as of the day before the expatriation or residency termination has been sold for its fair market value. Any net gain on the deemed sale is recognized to the extent it exceeds $680,000 (2014 exclusion amount).

With certain exceptions, “covered expatriates” include U.S. citizens who relinquish their citizenship or certain long-term U.S. permanent residents who terminate their residency if such individuals: (a) have relatively high tax liability (a 5-year average income tax bill of at least $147,000, adjusted annually for inflation thereafter); (b) have relatively high net worth ($2 million or more); or (c) either have not certified under penalties of perjury that they have complied with all U.S. federal tax obligations for the previous five years or have not submitted the requisite evidence of compliance.

Are there any tax consequences of me transferring money from USA to my say home country?

While, the transfer of money from one country to another does not carry a tax consequence, the exchange of one currency for another (i.e. USD for AUD) is a taxable event.

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Streamlined Offshore Procedures vs amended and delinquent filing

Jurate Gulbinas   |   19 Sep 2018   |   4 min read

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 and income, this limits avenues to coming into compliant with the U.S. tax requirements.

Clients with foreign holdings, financial assets and business holdings are often unaware of the stringent disclosure requirements in the US and it is very common for taxpayers to be entering into the various programs with the IRS to properly disclose financial assets.

Under certain circumstances and where a taxpayer was completely unaware of their disclosure and reporting requirements, this leaves the following options to get into compliance with IRS requirements:

c. Filing under the streamlined procedures; or

d. filing of delinquent FBARs and amended tax returns.

Streamlined procedures

The streamlined procedures include the streamlined domestic offshore procedures(SDOP) and streamlined foreign offshore procedures(SFOP). The streamlined domestic offshore procedure is available where a U.S. taxpayer does not meet the non-residency requirement contained in section 911 of the Internal Revenue Code (IRC) and is designed for U.S. taxpayers primarily residing in the U.S. The streamlined foreign offshore procedure is available where a U.S. taxpayer meets the non-residency requirement contained in section 911 of the IRC and is designed for U.S. taxpayers not living in the U.S.

The streamlined procedures require amending the last 3 years of tax returns to report undisclosed income from foreign assets, and filing FBAR disclosures for the last 6 years. The program also requires that a taxpayer files a statement to the satisfaction of the IRS that their noncompliance was non-willful. This is of particular importance as the taxpayer will do so under the penalty of perjury which can have criminal penalties. Making a fraudulent statement can carry substantial penalties and carry criminal charges.

In addition to payment of back-taxes, a miscellaneous offshore penalty of 5% is due under the SDOP. There is no miscellaneous penalty under the SFOP. The 5% penalty is on the highest aggregate balance of the taxpayer’s foreign financial assets that are subject to the miscellaneous offshore penalty during the years in the 3-year tax return period and the 6-year FBAR period. For this purpose, the highest aggregate balance is determined by aggregating the year-end account balances and year-end asset values of all the foreign financial assets subject to the miscellaneous offshore penalty for each of the covered years and selecting the highest aggregate balance from among those years.

As you can see, the streamlined procedures were designed for U.S. taxpayers that have non-willfully failed to disclose their foreign financial assets and foreign income.

Delinquent and amended filings

In certain circumstances, it can make more sense to file amended tax returns and delinquent FBARs outside of the streamlined procedures. This will generally be the case where you have foreign financial accounts that have not been disclosed, and where there is no additional income and therefore no further US tax liability.

In our experience, this may be the case where you have failed to disclose your superannuation on an FBAR, and you may need to include rental income from a foreign property in your U.S. tax return, however the property is generating losses.

Taxpayers should file delinquent FBARs if they do not need to use either the OVDP or the streamlined procedures to file delinquent or amended tax returns to report and pay additional tax, but who:

  • have not filed an FBAR,
  • are not under a civil examination or a criminal investigation by the IRS, and
  • have not already been contacted by the IRS about the delinquent FBARs

The IRS will not impose a penalty for the failure to file the delinquent FBARs if you have properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted.

The key requirement of filing delinquent FBARs is including a statement explaining why you are filing the FBARs late and that your failure to report is non-wilful. Willfulness has been defined by courts as “an intentional violation of a known legal duty”.

The IRS recommends that amended returns should be filed where a taxpayer has claimed the wrong filing status and has to change income, deductions or credits. This method is advisable where no further tax is due as you are able to disclose the correct income and information without penalties, tax and interest. To the extent further tax should be due upon amending the prior tax returns due to undisclosed income, you may not be able to file amended returns without penalties in which case the streamline process is advisable.

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Online Business with No Physical Presence May Be Liable for US Sales Tax


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UK tax hikes affecting expat property owners: is it too late to act?

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A lot of young people have a dream to travel the world. This is one person’s take on that. They did it and actually used it to get a career going. They were in their twenties. It’s pretty impressive to see someone of that age manage that successfully.

Key Takeaways:

  • Having worked in the consulting division of a huge multinational company, I know what it feels like to be plugging away in a cubicle in New York or Chicago.
  • Thanks to those years of global experience, it’s actually hard for me to get anything but an international job now.
  • Go abroad early in your career. Take any opportunity you can—take a salary cut if you have to, volunteer, do anything that “globalizes” your resume.

“Go abroad early in your career.”

https://www.fastcompany.com/3067658/lessons-learned/six-ways-i-built-a-career-traveling-the-world-in-my-20s?partner=rss

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9 Daily Habits of People Who Are Relentlessly Confident


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You are going to die, and when you die no one is going to remember that you didn’t answer the question right, no one is going to remember that you said something awkward after class. Remind yourself that you’re going to die, so you don’t take the small things so seriously.

Key Takeaways:

  • You are going to die, and when you die no one is going to remember that you didn’t answer the question right, no one is going to remember that you said something awkward after class.
  • It makes you get good at talking with confidence, and the teacher will make you do things that get you WAY out of your comfort zone.
  • When you’re talking to an old friend, you could be playing the nostalgia game. When you’re talking with a girl at the bar, you’re playing the flirting game.

“It makes you get good at talking with confidence, and the teacher will make you do things that get you WAY out of your comfort zone.”

http://www.inc.com/quora/9-daily-habits-of-people-who-are-relentlessly-confident.html

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More articles like this

 

Six Ways I Built A Career Traveling The World In My 20s


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