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OVDP ended on September 28, 2018; today, willful cases go through the IRS CI Volunta...
Today, many foreign investment vehicles can be classified as PFICs, including certain foreign mutual funds, index funds, ETFs, and investment structures held through foreign pension arrangements. ...
The IRS imposes a $10,000 initial penalty for not filing Form 5471 per tax year – regardless of whether any tax is owed (IRC §6038(b)). The penalty multiplies per foreign corporation: a taxpayer with three foreign corporations who misses one year faces $30,000 in initial penalties alone. In addition, a missed Form 5...
Foreign derived intangible income FDII is a Section 250 tax benefit that can lower the US tax rate on certain income earned by domestic corporations from serving foreign customers. In plain English, the FDII deduction is designed for qualifying foreign sal...
At a glance Who must file: US citizens who relinquish citizenship, long-term residents who end US tax residency, and certain individuals with ongoing reporting obligations for deferred tax, eligible d...
Assurance Vie can work well in France, but US expats need a second tax lens. French income-tax treatment improves after 8 years, FBAR review can start once foreign accounts exceed $10,000 in aggregate, and French withdrawal rules shift around the €150,000 premium threshold. US reporting may also reach Form 8938 and sometimes Form 8621. ...
