Over the past several years, the U.S. government has undertaken a sustained offensive against unreported offshore assets and income. Since the 2009 deferred-prosecution agreement between the U.S. Department of Justice and UBS AG, Switzerland’s largest bank (which UBS agreed to pay a $780 million [...]
The annual filing requirements for shareholders of a passive foreign investment company (PFIC) are in effect for the current tax season. The annual filing requirement is imposed on U.S. persons who are PFIC shareholders who do not currently file Form 8621, Information Return by [...]
The receipt of a gift or inheritance generally is not taxable income to the recipient. However, if you are a U.S. citizen or income tax resident and the value of aggregate gifts/inheritance you receive from a nonresident during any tax year exceeds a certain [...]
U.S. income taxation of foreign pension plans
The IRS recently released long-awaited proposed Regulations providing additional guidance on the implementation of the Foreign Account Tax Compliance Act (“FATCA”), which was passed by Congress in March 2010. The 388 pages of guidance provide additional detail on the rules that will apply to [...]
