The Internal Revenue Service (IRS) has announced that the Offshore Voluntary Compliance Program (OVDP) will terminate on September 28, 2018 (not the Streamlined Compliance Program). Once the OVDP ends the I.R.S. will be looking for offshore unreported income. The penalties, …
ATTENTION United States Taxpayers Residing Outside The United States Read more »
This is an extremely important and valuable I.R.S. Program. It allows almost every American who has been afraid to step forward and disclose their foreign assets to the U.S. taxing authorities to do so with minimized penalties on unpaid taxes and unfiled information returns.
The Technical Advice Memorandum reviewed the term “export property” for DISC purposes in depth and determined in its holding that computer software could indeed be “export property”.
The taxation of Americans and long term green card holders (permanent residents) who expatriate from the United States has gone through many changes over the years. The latest version of these changes with tax expatriating Americans on their accumulated un-taxed …
The Tax Planning for Expatriation from the United States Read more »
Since the U.S. tax rates are progressively higher as the income level is increased, the Foreign Investor may pay much less than what a U.S. Investor will pay on the same income, since the Foreign Investors’ real estate income may be in a lower tax bracket as the only U.S. income of the Investor.
Thus the magic of the IC-DISC is to provide both tax deferral and to apply a 15% maximum dividend tax rate to profits that would otherwise be taxable in the U.S. taxpayer’s highest brackets that can range as high as 50% . . .
The best rule to follow in the field of tax law is to plan legal matters and obtain precision advice in advance to insure commercial endeavors are completed at minimum tax costs and personal lives are minimally disrupted. This is even more the case in the international field. Make Richard S. Lehman, Esq., your in-house International Tax Law office — TODAY!
What is less familiar is the fact that an investor in a Ponzi Scheme cannot only lose all of their investment. Investors in Ponzi Schemes can also be forced to pay back additional moneys earned from the Ponzi Scheme years before it exploded. This is what is known as a clawback.
The immigrating Non Resident Alien must prepare for a tax life as a Resident Alien. This means taking advantage of all of the tax deductions and tax investment incentives offered by the U.S. Tax Code. It may actually mean leaving certain of the taxpayer’s foreign investments in place. This is also the subject of a separate article on the Taxation of Immigrating to the United States.
NEW U.S. TAX LAW Seminar Series: 5.5 hours FREE Continuing Education Course Credits These seminars cover a complete range of topics dealing with legal and practical advice for foreign investors that invest in United States businesses, United States real estate …