Numerous US individuals own overseas assets or have an interest in them. The IRS may penalize these taxpayers if they fail to report these assets on their tax filings. Consequently, the streamlined filing compliance procedure exists to assist these individuals with:
– A streamlined process to file delinquent or amended tax returns;
– Resolving tax and penalty procedures for filing delinquent or amended returns; and
– Resolving penalty and tax obligations
This webinar will guide you through the complexities of Streamlined Filing Compliance Procedures and make your US Tax Journey Exponentially easier!
Takeaways:
Topics that we will cover in the upcoming webinar:
1. Introduction to Streamlined filing
2. Eligibility Criteria for Streamlined Filing
3. Types of Streamlined Filing
– Streamlined Foreign Offshore Procedures
– Streamlined Domestic Procedures
4. Other rules and regulations
5. FAQs, and much more
Who Attended?
- US Citizens Living in the US and Outside
- CPAs, EAs, CAs, ACCAs
- Tax and Accounting Professionals with US Citizens as their clients
The document discusses major changes made by the IRS in 2014 to the Offshore Voluntary Disclosure Program and streamlined filing procedures. It expanded eligibility for the streamlined procedures to include more U.S. taxpayers, eliminated certain tax thresholds and risk assessment processes. There are now two types of streamlined procedures - one for taxpayers living abroad and one for taxpayers living in the U.S. The streamlined foreign procedures eliminate penalties for back taxes and interest, while the domestic procedures charge a reduced penalty of 5% of undisclosed foreign assets. The document outlines various eligibility requirements and potential issues or "traps" to be aware of for each streamlined procedure.
FBAR and US Taxes for Expatriates - Intercam Presentation , Ixtapa, MexicoDon Nelson Tax Attorney
- US citizens living abroad, including in Mexico, are required to file US tax returns and report foreign financial accounts over $10,000. Failure to do so can result in penalties.
- There are tax treaties between the US and Mexico to exchange tax information. The IRS is increasing audits of US expatriates due to inaccurate filings. It's important for expats to properly report all foreign income and assets.
- Expats have options if they have not filed previously, including streamlined filing programs. Filing past returns or disclosures without penalties is possible in some cases. Proper filing and documentation is important to avoid audits.
Reporting Requirements for US Citizens with Foreign Assetsgppcpa
The presentation reviews the reporting requirements for US citizens with foreign assets and the remedies for non-compliance. You will view the appropriate tax forms needed for reporting, due dates and penalty amounts. Te difference between willful and non-willful will be explained.
The document discusses cross-border tax planning and compliance for US persons living in Canada. It outlines how to determine US tax exposure based on citizenship, residency and foreign assets. US persons are required to file annual tax returns, FBARs, and disclosures of foreign accounts, investments and businesses. Failure to comply can result in penalties and criminal charges. Integrated planning is needed to structure assets and income to minimize US tax obligations while meeting Canadian regulations.
U.S. taxpayers living abroad have filing requirements regarding their overseas income and financial accounts. They must file annual tax returns reporting worldwide income and may qualify for the foreign earned income exclusion. The foreign tax credit allows taxpayers to claim taxes paid to foreign governments to avoid double taxation. Additionally, taxpayers with over $10,000 in foreign financial accounts must file an FBAR report and may need to report foreign assets on Form 8938 if thresholds are met. Failure to comply with these filing requirements can result in significant penalties.
Understanding US Expat - A Presentation to IFS AdvisorsDerren Joseph
This document provides an overview and summary of key issues relating to US expats. It introduces Derren Joseph, the presenter, and his qualifications. It then outlines the key points to be covered:
- Defining who is a US person for tax purposes, including citizens, permanent residents, and substantial presence tests.
- Distinguishing between citizenship-based and residency-based taxation and how this impacts expats.
- Highlighting issues with non-qualified insurance policies, PFICs, FBAR reporting requirements, and FATCA compliance for expats holding foreign financial accounts or assets.
- Providing brief summaries of the tax treatment and reporting obligations for these key areas that most impact
US Expatriate Tax Presentation given in Puerto Vallarta and Melaque Mexico for Americans living there concerning filing FBAR forms, form 8938 and other required IRS foreign reporting forms by Don D. Nelson, Attorney, CPA. His website at www.taxmeless.com has a wealth of additional information
The document discusses major changes made by the IRS in 2014 to the Offshore Voluntary Disclosure Program and streamlined filing procedures. It expanded eligibility for the streamlined procedures to include more U.S. taxpayers, eliminated certain tax thresholds and risk assessment processes. There are now two types of streamlined procedures - one for taxpayers living abroad and one for taxpayers living in the U.S. The streamlined foreign procedures eliminate penalties for back taxes and interest, while the domestic procedures charge a reduced penalty of 5% of undisclosed foreign assets. The document outlines various eligibility requirements and potential issues or "traps" to be aware of for each streamlined procedure.
FBAR and US Taxes for Expatriates - Intercam Presentation , Ixtapa, MexicoDon Nelson Tax Attorney
- US citizens living abroad, including in Mexico, are required to file US tax returns and report foreign financial accounts over $10,000. Failure to do so can result in penalties.
- There are tax treaties between the US and Mexico to exchange tax information. The IRS is increasing audits of US expatriates due to inaccurate filings. It's important for expats to properly report all foreign income and assets.
- Expats have options if they have not filed previously, including streamlined filing programs. Filing past returns or disclosures without penalties is possible in some cases. Proper filing and documentation is important to avoid audits.
Reporting Requirements for US Citizens with Foreign Assetsgppcpa
The presentation reviews the reporting requirements for US citizens with foreign assets and the remedies for non-compliance. You will view the appropriate tax forms needed for reporting, due dates and penalty amounts. Te difference between willful and non-willful will be explained.
The document discusses cross-border tax planning and compliance for US persons living in Canada. It outlines how to determine US tax exposure based on citizenship, residency and foreign assets. US persons are required to file annual tax returns, FBARs, and disclosures of foreign accounts, investments and businesses. Failure to comply can result in penalties and criminal charges. Integrated planning is needed to structure assets and income to minimize US tax obligations while meeting Canadian regulations.
U.S. taxpayers living abroad have filing requirements regarding their overseas income and financial accounts. They must file annual tax returns reporting worldwide income and may qualify for the foreign earned income exclusion. The foreign tax credit allows taxpayers to claim taxes paid to foreign governments to avoid double taxation. Additionally, taxpayers with over $10,000 in foreign financial accounts must file an FBAR report and may need to report foreign assets on Form 8938 if thresholds are met. Failure to comply with these filing requirements can result in significant penalties.
Understanding US Expat - A Presentation to IFS AdvisorsDerren Joseph
This document provides an overview and summary of key issues relating to US expats. It introduces Derren Joseph, the presenter, and his qualifications. It then outlines the key points to be covered:
- Defining who is a US person for tax purposes, including citizens, permanent residents, and substantial presence tests.
- Distinguishing between citizenship-based and residency-based taxation and how this impacts expats.
- Highlighting issues with non-qualified insurance policies, PFICs, FBAR reporting requirements, and FATCA compliance for expats holding foreign financial accounts or assets.
- Providing brief summaries of the tax treatment and reporting obligations for these key areas that most impact
US Expatriate Tax Presentation given in Puerto Vallarta and Melaque Mexico for Americans living there concerning filing FBAR forms, form 8938 and other required IRS foreign reporting forms by Don D. Nelson, Attorney, CPA. His website at www.taxmeless.com has a wealth of additional information
Introduction to Taxation of Foreign Investment in U.S. Real EstateSmart Accountants
This webinar introduces some of the most important tax issues that non-US investors in U.S. real estate should consider.
You will learn:
- Introductions to US Real Estate investment by Foreign Investor
- FDAP income (Not trade or business income)
- Effectively Connected Income (ECI)
- Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
- Choice of proper investment structure and tax planning
- Tax Implications for:- Rental income tax- Capital Gain Tax on the eventual disposition of property- Estate/Gift tax consequences
- Other consideration- Anonymity – Nondisclosure of the identity- Assets protection- The simplicity of the structure balances against complexity costs.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
This presentation discusses US taxation. It covers various taxing entities in the US, types of taxes including income, estate, gift and sales taxes. It discusses how income is taxed for individuals and corporations. It also covers topics like FBAR reporting for foreign accounts, social security taxes, the home sale exclusion, deferred compensation rules, and standard US tax forms. The presentation is intended for discussion purposes only and does not replace personalized tax advice.
Americans face many investing challenges while living in the UK. They require help with keeping constant vigilance on rules and regulations. Get in touch with a Maseco financial advisor expert today to see how we can help you get a handle on your domestic and foreign investments.
Expatriation and voluntary disclosure update 2012Dave Turchen
This document provides an overview and discussion of U.S. expatriation and voluntary disclosure processes. It defines who qualifies as a U.S. expatriate, outlines the tax consequences and reporting requirements of expatriation, and discusses planning considerations. It also reviews the U.S. voluntary disclosure program options, including the 2012 Offshore Voluntary Disclosure Program, new streamlined filing compliance procedures, and other potential options. The document concludes with a discussion of conducting a situational analysis to determine the best disclosure option.
The document provides an overview and update on international taxation rules for cross-border transactions. It discusses key concepts like controlled foreign corporations, foreign tax credits, FACTA requirements, and filing requirements for outbound and inbound international transactions. Failure to comply with foreign reporting rules can result in civil and in some cases criminal penalties. The presentation aims to help people understand and properly adhere to the complex IRS regulations for international tax compliance.
International Tax and Transfer Pricing TopicsSkoda Minotti
This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Estate and Gift Tax Issues.
Planning for move to U.S.
Estate/gift tax residency.
Estate/gift tax applicability for NRA’s and for U.S. residents.
Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
Considerations Prior to moving to U.S.
Considerations related to negotiating compensation arrangements/benefits/tax equalization agreements/etc. before moving to the U.S.
Determining taxation and differences of taxation for U.S. residents vs. non-residents.
U.S./State taxation of foreign nationals.
U.S. residency vs non-residency for income tax purposes.
U.S. taxation of U.S. persons vs NRAs.
Substantial Presence Test.
Closer Connection Exception.
Dual Status Returns.
First Year Elections.
This document discusses key information reporting requirements and changes for 2016, including:
- Form 1098 reporting now requires property address, outstanding mortgage principal, and origination date.
- Form 1099-MISC due date for non-employee compensation in Box 7 changed to January 31, 2017.
- Mergers and acquisitions information reporting must be addressed in agreements, and successor entities may combine predecessor reporting in some cases.
- Substantial penalties apply for failure to file correct and timely information returns. Reasonable cause can sometimes waive penalties.
The document provides an overview of filing US federal taxes, including determining tax residence status, available credits and deductions, social security numbers, foreign income reporting, retirement plans, and health savings accounts. It notes important details like tax law changes, eligibility for the foreign tax credit, and reporting capital gains from foreign property sales. Filers are advised to disclose all relevant tax information to their preparer and try to work with someone available year-round.
While residing in the UK, US citizens have numerous investing hurdles. They must remain vigilant about laws and regulations at all times. Contact a Maseco US UK financial advisor today to learn how we can assist you in managing your domestic and international investments.
Sending U.S. Employees Overseas: Tax and Immigration Update Eliot Norman
This document provides an overview and agenda for a presentation on sending U.S. employees overseas. It covers topics such as U.S. expatriate taxation basics, U.S. immigration for expatriates basics, the impact of recent tax legislation, recent immigration developments, foreign financial reporting, and the Foreign Account Tax Compliance Act (FATCA) and what it means for U.S. expatriates. The presentation agenda includes slides on U.S. expatriate taxation, U.S. immigration visas and permits, tax equalization, the foreign earned income exclusion, foreign tax credits, income tax treaties, and reporting requirements for foreign financial accounts.
This document discusses financial planning considerations under the Foreign Account Tax Compliance Act (FATCA). It begins by introducing Derren Joseph, the author, and his qualifications. It then provides an outline of topics to be covered, including what constitutes a US person, what FATCA is, its implications for US persons, points of compliance like non-qualified insurance policies, PFICs, and FBARs. The document discusses the impact of FATCA through surveys showing closed accounts and issues obtaining services. It provides details on FATCA requirements and compliance issues for various financial assets and reporting forms.
Big John, a U.S. citizen living in the Philippines, must file several IRS forms to report his foreign income and bank accounts. These include Form 1040 to report worldwide income, as well as FBAR and FATCA forms to disclose foreign bank accounts and financial assets. Failure to file these informational forms can result in penalties from the IRS, even if no tax is due. The presentation provides examples and thresholds for when these various forms are required.
International Students/Faculty/Staff Tax Workshop 2016UTSA_International
This document provides information about taxation for non-resident aliens. It defines key terms like non-resident alien, US resident, non-resident alien for tax purposes, and resident alien for tax purposes. It also outlines the substantial presence test and green card test to determine residency status. The document discusses forms like 1042-S, 1040NR-EZ, 1040NR, 8843, and W7 that may need to be filed. It provides guidance on income types, exemptions, deductions, and the Glacier Tax Prep software for filing taxes.
Big John, a U.S. citizen living in the Philippines, must file several IRS forms to report his foreign income and bank accounts. These include Form 1040 to report worldwide income to the IRS. He may also need to file Form 1116 if he paid foreign taxes, and Forms 3520 or 3520-A to report any foreign trusts or corporations he has an interest in. Big John must file an FBAR if he has over $10,000 in foreign bank accounts, and may need to report foreign accounts under FATCA as well. Failure to file these informational forms can result in penalties from the IRS.
This document discusses the key fiscal obligations of U.S. citizens residing in Spain. It notes that Americans living abroad have increased to over 7.6 million in 2014 and over 8.7 million in 2015. It then summarizes the main forms and reports required, including the Form 1040 tax return, Foreign Bank Account Report (FBAR), Spanish tax return (Modelo 100), and the Spanish asset reporting form (Modelo 720). The document provides brief descriptions of when each form is due and what types of income and accounts must be disclosed.
Canadian Tax System & Doing Business in Ontario - February 25, 2013 Seminar (...Sonja Chong FCA, TEP
This document provides information about the Canadian tax system and doing business in Ontario. It discusses who is liable to pay tax in Canada, the concept of worldwide income for tax residents, and definitions of foreign affiliates and controlled foreign affiliates. It also summarizes considerations for business structure selection, tax rates for businesses in Ontario, and tax planning strategies for new tax residents. Record keeping requirements and types of tax and information returns are outlined.
OJP data from firms like Vicinity Jobs have emerged as a complement to traditional sources of labour demand data, such as the Job Vacancy and Wages Survey (JVWS). Ibrahim Abuallail, PhD Candidate, University of Ottawa, presented research relating to bias in OJPs and a proposed approach to effectively adjust OJP data to complement existing official data (such as from the JVWS) and improve the measurement of labour demand.
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Introduction to Taxation of Foreign Investment in U.S. Real EstateSmart Accountants
This webinar introduces some of the most important tax issues that non-US investors in U.S. real estate should consider.
You will learn:
- Introductions to US Real Estate investment by Foreign Investor
- FDAP income (Not trade or business income)
- Effectively Connected Income (ECI)
- Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
- Choice of proper investment structure and tax planning
- Tax Implications for:- Rental income tax- Capital Gain Tax on the eventual disposition of property- Estate/Gift tax consequences
- Other consideration- Anonymity – Nondisclosure of the identity- Assets protection- The simplicity of the structure balances against complexity costs.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
This presentation discusses US taxation. It covers various taxing entities in the US, types of taxes including income, estate, gift and sales taxes. It discusses how income is taxed for individuals and corporations. It also covers topics like FBAR reporting for foreign accounts, social security taxes, the home sale exclusion, deferred compensation rules, and standard US tax forms. The presentation is intended for discussion purposes only and does not replace personalized tax advice.
Americans face many investing challenges while living in the UK. They require help with keeping constant vigilance on rules and regulations. Get in touch with a Maseco financial advisor expert today to see how we can help you get a handle on your domestic and foreign investments.
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This document provides an overview and discussion of U.S. expatriation and voluntary disclosure processes. It defines who qualifies as a U.S. expatriate, outlines the tax consequences and reporting requirements of expatriation, and discusses planning considerations. It also reviews the U.S. voluntary disclosure program options, including the 2012 Offshore Voluntary Disclosure Program, new streamlined filing compliance procedures, and other potential options. The document concludes with a discussion of conducting a situational analysis to determine the best disclosure option.
The document provides an overview and update on international taxation rules for cross-border transactions. It discusses key concepts like controlled foreign corporations, foreign tax credits, FACTA requirements, and filing requirements for outbound and inbound international transactions. Failure to comply with foreign reporting rules can result in civil and in some cases criminal penalties. The presentation aims to help people understand and properly adhere to the complex IRS regulations for international tax compliance.
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This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Estate and Gift Tax Issues.
Planning for move to U.S.
Estate/gift tax residency.
Estate/gift tax applicability for NRA’s and for U.S. residents.
Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
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Determining taxation and differences of taxation for U.S. residents vs. non-residents.
U.S./State taxation of foreign nationals.
U.S. residency vs non-residency for income tax purposes.
U.S. taxation of U.S. persons vs NRAs.
Substantial Presence Test.
Closer Connection Exception.
Dual Status Returns.
First Year Elections.
This document discusses key information reporting requirements and changes for 2016, including:
- Form 1098 reporting now requires property address, outstanding mortgage principal, and origination date.
- Form 1099-MISC due date for non-employee compensation in Box 7 changed to January 31, 2017.
- Mergers and acquisitions information reporting must be addressed in agreements, and successor entities may combine predecessor reporting in some cases.
- Substantial penalties apply for failure to file correct and timely information returns. Reasonable cause can sometimes waive penalties.
The document provides an overview of filing US federal taxes, including determining tax residence status, available credits and deductions, social security numbers, foreign income reporting, retirement plans, and health savings accounts. It notes important details like tax law changes, eligibility for the foreign tax credit, and reporting capital gains from foreign property sales. Filers are advised to disclose all relevant tax information to their preparer and try to work with someone available year-round.
While residing in the UK, US citizens have numerous investing hurdles. They must remain vigilant about laws and regulations at all times. Contact a Maseco US UK financial advisor today to learn how we can assist you in managing your domestic and international investments.
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This document provides an overview and agenda for a presentation on sending U.S. employees overseas. It covers topics such as U.S. expatriate taxation basics, U.S. immigration for expatriates basics, the impact of recent tax legislation, recent immigration developments, foreign financial reporting, and the Foreign Account Tax Compliance Act (FATCA) and what it means for U.S. expatriates. The presentation agenda includes slides on U.S. expatriate taxation, U.S. immigration visas and permits, tax equalization, the foreign earned income exclusion, foreign tax credits, income tax treaties, and reporting requirements for foreign financial accounts.
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Big John, a U.S. citizen living in the Philippines, must file several IRS forms to report his foreign income and bank accounts. These include Form 1040 to report worldwide income, as well as FBAR and FATCA forms to disclose foreign bank accounts and financial assets. Failure to file these informational forms can result in penalties from the IRS, even if no tax is due. The presentation provides examples and thresholds for when these various forms are required.
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Big John, a U.S. citizen living in the Philippines, must file several IRS forms to report his foreign income and bank accounts. These include Form 1040 to report worldwide income to the IRS. He may also need to file Form 1116 if he paid foreign taxes, and Forms 3520 or 3520-A to report any foreign trusts or corporations he has an interest in. Big John must file an FBAR if he has over $10,000 in foreign bank accounts, and may need to report foreign accounts under FATCA as well. Failure to file these informational forms can result in penalties from the IRS.
This document discusses the key fiscal obligations of U.S. citizens residing in Spain. It notes that Americans living abroad have increased to over 7.6 million in 2014 and over 8.7 million in 2015. It then summarizes the main forms and reports required, including the Form 1040 tax return, Foreign Bank Account Report (FBAR), Spanish tax return (Modelo 100), and the Spanish asset reporting form (Modelo 720). The document provides brief descriptions of when each form is due and what types of income and accounts must be disclosed.
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OJP data from firms like Vicinity Jobs have emerged as a complement to traditional sources of labour demand data, such as the Job Vacancy and Wages Survey (JVWS). Ibrahim Abuallail, PhD Candidate, University of Ottawa, presented research relating to bias in OJPs and a proposed approach to effectively adjust OJP data to complement existing official data (such as from the JVWS) and improve the measurement of labour demand.
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1. Elemental Economics - Introduction to mining.pdfNeal Brewster
After this first you should: Understand the nature of mining; have an awareness of the industry’s boundaries, corporate structure and size; appreciation the complex motivations and objectives of the industries’ various participants; know how mineral reserves are defined and estimated, and how they evolve over time.
Seminar: Gender Board Diversity through Ownership NetworksGRAPE
Seminar on gender diversity spillovers through ownership networks at FAME|GRAPE. Presenting novel research. Studies in economics and management using econometrics methods.
[4:55 p.m.] Bryan Oates
OJPs are becoming a critical resource for policy-makers and researchers who study the labour market. LMIC continues to work with Vicinity Jobs’ data on OJPs, which can be explored in our Canadian Job Trends Dashboard. Valuable insights have been gained through our analysis of OJP data, including LMIC research lead
Suzanne Spiteri’s recent report on improving the quality and accessibility of job postings to reduce employment barriers for neurodivergent people.
Decoding job postings: Improving accessibility for neurodivergent job seekers
Improving the quality and accessibility of job postings is one way to reduce employment barriers for neurodivergent people.
Independent Study - College of Wooster Research (2023-2024) FDI, Culture, Glo...AntoniaOwensDetwiler
"Does Foreign Direct Investment Negatively Affect Preservation of Culture in the Global South? Case Studies in Thailand and Cambodia."
Do elements of globalization, such as Foreign Direct Investment (FDI), negatively affect the ability of countries in the Global South to preserve their culture? This research aims to answer this question by employing a cross-sectional comparative case study analysis utilizing methods of difference. Thailand and Cambodia are compared as they are in the same region and have a similar culture. The metric of difference between Thailand and Cambodia is their ability to preserve their culture. This ability is operationalized by their respective attitudes towards FDI; Thailand imposes stringent regulations and limitations on FDI while Cambodia does not hesitate to accept most FDI and imposes fewer limitations. The evidence from this study suggests that FDI from globally influential countries with high gross domestic products (GDPs) (e.g. China, U.S.) challenges the ability of countries with lower GDPs (e.g. Cambodia) to protect their culture. Furthermore, the ability, or lack thereof, of the receiving countries to protect their culture is amplified by the existence and implementation of restrictive FDI policies imposed by their governments.
My study abroad in Bali, Indonesia, inspired this research topic as I noticed how globalization is changing the culture of its people. I learned their language and way of life which helped me understand the beauty and importance of cultural preservation. I believe we could all benefit from learning new perspectives as they could help us ideate solutions to contemporary issues and empathize with others.
Lecture slide titled Fraud Risk Mitigation, Webinar Lecture Delivered at the Society for West African Internal Audit Practitioners (SWAIAP) on Wednesday, November 8, 2023.
2. Elemental Economics - Mineral demand.pdfNeal Brewster
After this second you should be able to: Explain the main determinants of demand for any mineral product, and their relative importance; recognise and explain how demand for any product is likely to change with economic activity; recognise and explain the roles of technology and relative prices in influencing demand; be able to explain the differences between the rates of growth of demand for different products.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Understanding how timely GST payments influence a lender's decision to approve loans, this topic explores the correlation between GST compliance and creditworthiness. It highlights how consistent GST payments can enhance a business's financial credibility, potentially leading to higher chances of loan approval.
Vicinity Jobs’ data includes more than three million 2023 OJPs and thousands of skills. Most skills appear in less than 0.02% of job postings, so most postings rely on a small subset of commonly used terms, like teamwork.
Laura Adkins-Hackett, Economist, LMIC, and Sukriti Trehan, Data Scientist, LMIC, presented their research exploring trends in the skills listed in OJPs to develop a deeper understanding of in-demand skills. This research project uses pointwise mutual information and other methods to extract more information about common skills from the relationships between skills, occupations and regions.
Does teamwork really matter? Looking beyond the job posting to understand lab...
Streamlined Filing Compliance Procedures
1.
2. Webinar Overview:
Responsibility of US
Citizen and Residents
Foreign Assets Disclosure
and Reporting
Getting to know
Streamlined Foreign
Streamlined Programs:
Remediation Eligibility
Streamlined Foreign
Offshore Procedures
Form 8938
Streamlined Domestic
Offshore Procedures
Who Is
Ineligible?
Form 8865
FBAR
Form 5471
Trap for the
Unwary
Form 926
Form 3520
Who is a U.S.
Taxpayer?
& much more!
3. • U.S. Citizens
• Lawful permanent residents – Green Card holder
• Those satisfying the substantial presence test of IRC section 7701(b)(3).
Who is a U.S. Taxpayer?
To meet this test, a person must be physically present in the United States on at least:
1. 31days during the current year, and
2. 183 days during the 3-year period that includes the current year and the 2 years immediately
before that, considering:
- All the days a person was present in the current year, and
- One -Third (1/3) of the days a person was present in the first year before the current year, and
- One - Sixth (1/6) of the days a person in the second year before the current year.
4. • File income tax returns reporting worldwide income (Form 1040)
• File required US international informational tax returns
• File FBARs on FinCen Form 114
Responsibility of US Citizen
and Residents
5. • Form 3520 Annual Return to report transactions with foreign trust and receipt of certain foreign gift
• Form 926 Return by a U.S Transferor of property to a foreign corporation
• Form 5471 Information Return of U.S. persons with respect to certain foreign corporations
• Form 8865 Return of U.S. person with respect to certain foreign partnerships
• Form 8621 PFICs
• FBAR
• Form 8938 Foreign Financial Assets
Foreign Assets Disclosure
and Reporting
6. • Under IRC 6048, taxpayers must report various transactions involving foreign trusts,
including the creation of a foreign trust by a United States person, transfers of property from
a United States person to a foreign trust, and receipt of distributions from foreign trusts.
• This return also reports the receipt of gifts from foreign entities under IRC 6093F.
• The penalty for returns reporting gifts is five percent of the gift per month, up to a maximum
penalty of 25 percent of the gift.
Form 3520
Annual Return to Report Transactions With Foreign
Trusts and Receipt of Certain Foreign Gifts
7. • Under IRC 6038B, taxpayers must report transfers of property to foreign corporations and other
information.
• The penalty for failing to file each one of these information returns is ten percent of the value of the
property transferred, up to a maximum of $100,000 per return, with no limit if the failure to report the
transfer was intentional.
Form 926
Return by a U.S. Transferor of Property to a Foreign
Corporation
8. • Under IRC $ 6035, 6038 and 6046, certain United States persons who are officers, directors or
shareholders in certain foreign corporations (including International Business Corporations) must
report information.
• The penalty for failing to file each one of these information returns is $10,000, with an additional
$10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of
the delinquency, up to a maximum of $50,000 per return.
Form 5471
Information Return of U.S. Persons with Respect to
Certain Foreign Corporations
9. • Under IRC $ 6038, 6038B, and 6046A, United States persons with certain interests in foreign
partnerships must report interests in and transactions of these foreign partnerships, transfers of
property to these foreign partnerships, and acquisitions, dispositions and changes in foreign
partnership interests.
• Penalties include $10,000 for failure to file each return, with an additional $10,000 added for each
month the failure continues beginning 90 days after the taxpayer is notified of the delinquency.
• The penalty is capped at $50,000 per return, and ten percent of the value of any transferred property
that is not reported, subject to a $100,000 limit.
Form 8865
Return of U.S. Persons with Respect to Certain
Foreign Partnerships
10. Individuals Must Must File FBARs if they Have:
• Financial Interest in, Signatory Authority or Other Authority Over One or More Accounts
(Bank Accounts, Brokerage Accounts, Mutual Fund Accounts) in a Foreign Country
FBAR
A person who willfully fails to file an FBAR or files an incomplete or incorrect FBAR, may be
subject to a civil monetary penalty of $100,000 or 50% of the balance in the account at the
time of the violation, whichever is greater. Willful violations may also be subject to criminal
penalties.
Who Must Report?
Penalty
11. Form 8938
A specified foreign financial asset (SFFA) is:
• Any financial account maintained by a foreign financial institution
– Foreign bank accounts
– Foreign mutual funds
– Foreign hedge funds
– Foreign private equity funds
– Certain foreign insurance products
• In general, Form 8938 penalties will be $10,000 per year.
Penalty
12. • IRS’s latest efforts is to promote tax compliance and to crack down on offshore tax evasion
• These program will ease the financial and legal pain for expatriate Americans who live and
work abroad
• They relax the penalties that a taxpayer with an overseas account might otherwise face for
failing to disclose a foreign account
Efforts by IRS
Never Underestimate What Information The IRS Can Find Out on its Own:
• Tax Return Preparer Must Forewarn Clients About the Increasing Breadth of Information
That Can Be Gathered by IRS, and Department of Justice (DOJ) on Noncompliant Taxpayers
Through Social Media
• Foreign Bankers Are Often meticulous in Keeping Notes of Prior Phone Calls and Meetings
with Clients or Advisors
• No Such Thing as a Secret Account
• Taxpayer Must be prepared to Credibly Explain to IRS Why They Failed to Disclose Foreign
Accounts and Why They Did Not Make a Voluntary Disclosure?
What Does the IRS Know?
13. Streamlined Programs:
Remediation Eligibility
• Streamlined Programs Initiated in 2012
• Technically Two Programs
1. Streamlined Domestic Offshore Procedures
2. Streamlined Foreign Offshore Procedures
• Common Theme of Both Programs is Requirement That Taxpayer Certify Under Penalty of
Perjury That His Conduct Was Not Willful – Conduct was due to negligence, or mistake or
conduct that is the result of good faith misunderstanding of the requirements of the law,
accidental failure to report
• IRS does not explicitly define “non-willful”. They review each case on an individual basis
• Only available to Individual and Estate (Not entities)
• Always include a certification narrative (reasonable cause statement) and attach Form 14654
or 14653
• Failed to report foreign financial assets and pay taxes
14. Streamlined Domestic
Offshore Procedures
• IRS extended streamline procedure to American Living in the U.S. with undisclosed foreign
accounts who previously were ineligible from participating in the streamlined procedure
• Such person who come forward now will owe back taxes, interest, and a reduce
“miscellaneous offshore penalty” equal to five percent of their undisclosed foreign financial
assets.
• Taxpayers Residing In US Requires Taxpayer to Have Filed Prior US Tax Returns for Most
Recent 3 Years AND
• Limited to Filing Amended Returns (No Original Returns Permitted if None Originally Filed),
AND
• Carries a Potential 5% Miscellaneous Penalty for Unreported Account/Assets
15. Getting to Know
Streamlined Domestic
• For each of the most recent three years for which the U.S. tax return due date – or extended
due date - has passed (the "covered tax return period"), file amended tax returns, together
with all required information returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and
8621);
• For each of the most recent six years for which the FBAR due date has passed (the "covered
FBAR period"), file any delinquent FBARS; and
• Pay a miscellaneous offshore penalty. The full amount of the tax, interest, and miscellaneous
offshore penalty should be submitted with the amended tax returns.
What must I submit?
16. Miscellaneous Offshore Penalty
for Streamlined Domestic
1. How is the miscellaneous offshore penalty calculated?
— It is equal to 5 percent of the highest aggregate balance of the taxpayer’s foreign financial
assets that are subject to the penalty during the years in the covered tax return period and the
covered FBAR period.
2. How is the highest aggregate balance determined?
— By tallying the year-end account balances and year-end asset values of all the foreign financial
assets subject to the penalty for each year in the covered tax return period and the covered FBAR
period and selecting the highest aggregate balance from among those years.
17. Streamlined Foreign
Offshore Procedures
• U.S. taxpayers must satisfy the following requirements:
• The applicable non-residency requirement (for joint return filers, both spouses must
satisfy the non-residency requirement); and
• Have failed to file an FBAR with respect to a foreign financial account; OR foreign
investment related informational forms, and
• The failure to file an FBAR/Foreign investment related forms must have resulted from
non willful conduct.
• U.S. Taxpayer living abroad who disclose their foreign accounts and settle their tax bills
under Streamlined Foreign Offshore Procedure won’t be charged any penalties.
Instead, they will simply owe back taxes and interest.
• File 3 years of delinquent or amended tax or information return and pay tax and interest
• File 6 years of delinquent FBARs
18. Getting to know
Streamlined Foreign
• First, the taxpayer must have a non-U.S. abode.
• Second, the taxpayer must have lived outside of the U.S. for 330 full days or more in at least
one of the most recent three years for which the U.S. tax return due date (or properly applied
for extended due date) has passed.
The non-residency requirement has two strands:
A helpful formula that illustrates the extreme scenario:
Satisfaction of non-residency requirement.
Up to 365 days in the U.S. in year one (or
any other year of the look-back period)
Up to 365 days in the U.S. in year two (or
any other year of the look-back period)
At least 330 days (or more) outside of the
U.S. in year three (or any year of the look-
back period).
(+)
(+)
19. • A taxpayer who spends 36 days in the U.S. in year one, 36 days in the U.S. in year two, and 36
days in the U.S. in year three fails the nonresidency requirement.
• Why? Because there are 365 days in a year and in no year could he have spent at least 330
days outside of the United States. Instead, the maximum number of days that he spent
outside of the U.S. in each year was 329 days, one day shy of the 330-day threshold.
• As you can see, the rigid requirements of the nonresidency requirement can play the role of
“spoiler” to well intentioned taxpayers wanting to "get right” with the IRS.
Getting to Know
Streamlined Foreign
Example #2:
20. • Is the taxpayer in example 2 who is deemed ineligible for streamlined foreign, eligible for
streamlined domestic?
• Only if he has filed his U.S. tax returns for each of the most recent three years for which the
U.S. tax return due date - or extended due date - has passed (a key requirement for
streamlined domestic)
• If the taxpayer in example 2 filed U.S. tax returns in two of the most recent three years for
which the U.S. tax return due date has passed, but neglected to do so in just one year, not
only would he be ineligible for streamlined foreign but he would also be ineligible for
streamlined domestic!
Getting to Know
Streamlined Foreign
Interesting question to ponder:
21. Getting to Know
Streamlined Foreign
• U.S. taxpayer must file delinquent or amended tax returns, together with all required
information returns (e.g, Forms 3520, 5471, and 8938) for each of the most recent three years
for which the U.S. tax return due date – or extended due date – has passed; and
• File any delinquent FBARs for each of the most recent six years for which the FBAR due date
has passed.
Remaining Requirements
22. A. 3 Years
B. 6 Years
Polling Question:
How Many years of delinquent FBAR needs to be
filed in Streamline Compliance Procedure?
23. Streamlined Assets
• Streamlined Assets refers to the assets which are reportable either on FBAR or Form 8938.
• Some assets like personal real estate investment in foreign country are not included
• Other assets such as Canadian RRSP (Registered Retirement Saving Plan) is included on the
FBAR and Form 8938 but NOT computed as part of the penalty. (Elect income deferral on
retirement plans permitted by Treaty)
24. IRS Audit and Verification
Returns submitted under either the foreign or domestic offshore procedures are not
automatically selected for audit. Instead, they are subject to “verification.”
• Through verification, the examining agent can request account statements and other
relevant documents to verify the information reported.
• However, this does not mean that an examination is impossible. On the contrary, such
returns may be selected for audit under the existing audit selection processes applicable to
any U.S. tax return
Taxpayers who are eligible to use the streamlined procedures and who follow all of the
instructions are not subject to failure-to-file and failure-to-pay penalties, accuracy-related
penalties, information return penalties, or FBAR penalties, even if their returns are
subsequently selected for audit.
• First, any previously assessed penalties relating to the years that are selected for audit will
not be abated.
• Second, to the extent that the IRS determines an additional tax deficiency for a return
submitted under these procedures, it can assert additional tax and penalties relating to that
additional deficiency.
• Finally, the IRS will unleash the full arsenal of penalties if it determines that the original tax
noncompliance was due to fraud and/or that the FBAR violation was willful.
25. IRS Audit and Verification
• Tax returns will be processed no different than any other returns submitted to the IRS.
Reading between the lines, what the IRS seems to suggest is not to expect confirmation for
receipt of the returns.
• Assuming a taxpayer's streamlined submission is rejected, the only remaining option for
coming into compliance with one's U.S. tax obligations is to file amended 1040s and
delinquent international returns in what is known as a “quiet disclosure.”
• With respect to the Streamlined Domestic Offshore Procedures, the five-percent
miscellaneous penalty is imposed on a broader base of foreign assets - not just those relating
to FBAR reporting.
26. Who Is Ineligible?
• Those taxpayers who cannot certify that their failure to report all income, pay all tax, and
submit all required information returns was due to nonwillful conduct.
• Those taxpayers who are under criminal investigation by IRS Criminal Investigation.
• Those taxpayers who are undergoing a civil examination, regardless of whether that
examination relates to unreported foreign assets.
27. A. Yes
B. No
Polling Question:
Is late filing and late payment penalties applicable
for tax returns filed under Streamlined Filing
Procedures?
29. For those interested in learning
more, asking questions or
signing up for one of our groups
or trainings,
NEXT STEPS:
Stay in the meeting after the end
OR schedule some time to talk:
Email: info@smartaccts.com | Phone: +1 850 788 2090
Editor's Notes
More than 1,000 streamlined submission since the program introduced in 2014.
On July 1, 2014 the IRS expanded and modified the Streamlined Filing Compliance Procedures first implemented on September 1, 2012 to US individual taxpayers residing outside the United States.
Non-willful – personal back ground, financial background, anything else you believe is relevant to your failure to report all required information returns including FBARS
how you acquired foreign financial assets, whether purchased, inherited,….
Form 3520 is an informational return that U.S. taxpayers report transactions of certain foreign trusts, ownership of foreign trusts, and receipts of large gifts from foreign entities. Typically, there are three reasons you might file Form 3520, you’re a U.S. owner of a foreign trust, you make certain transactions with a foreign trust, and/or you receive a large gift or inheritance from certain overseas persons.
3520-A – Foreign trust annual reporting
Form 3520 – Foreign Gifts and Trusts - Required to be filed by any U.S. person who: Received a gift of more than $100,000 from an NRA
Most often missed out
Many tax software does not include this form
Most common instant when required is when US shareholder become shareholder in foreign corporation
Reports transfer of cash or property
Form 5471 - CFC - Required to be filed by a U.S. person who controls, transacts with or has certain relationships with the CFC
Depending upon ownership percentage in foreign corporation various schedules are applicable
Ownership in foreign partnership, again depending upon ownership percentage and whether acquired or disposed of interest during the year there are various categories which determines which schedules needs to be reported
Reporting requirement
Items to include and report
Not with tax return
Files with tax return
Filing requirement is different depending upon filing status and whether you are residing within US OR outside US
Much broader definition
FATCA signed by various countries – enacted in 2010 – total 113 countries have signed this and can exchange the information
A taxpayer who is eligible to use these Streamlined Procedures and who complies with all of the instructions will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties, or FBAR penalties.
In order to be eligible for the Streamline Foreign Offshore Procedure, the IRS should not have initiated a civil examination of taxpayer's returns for any taxable year. If the taxpayer is already under audit, the taxpayer is ineligible for the program.
Include at the top of the first page of each amended tax return and at the top of each information return
"Streamlined Domestic Offshore"-14654 OR "Streamlined Foreign Offshore"-14653
written in red to indicate that the returns are being submitted under these procedures.
This is critical to ensure that your returns are processed through these special procedures.
Tax return together with the payments if any, must be sent in paper form
FBAR must be filed electronically
we recommend:
Select an experienced expat tax accountant to save time, ensure accuracy, and avoid the risk of an audit
Organize your tax documents (for the past three years)
Gather statements from your foreign financial accounts (for the past six years) - On the cover page of the electronic form, select "other" as the reason for filing late, and in the explanation box that opens, enter "Streamlined Filing Compliance Procedures."