In my last blog entry I described how a virtually unknown Treasury agency, the Financial Crimes Enforcement Network, has issued proposed regulations that would change the offshore investment reporting requirements for U.S. taxpayers. The rules are slated to become effective well before the June 30, 2010 filing deadline for Treasury Form TD F 90-22.1, the “foreign bank account reporting” form, or FBAR. That means they would apply retroactively to 2009.
Last week, the U.S. Treasury finally clarified exactly what it expects U.S. taxpayers to disclose about their offshore holdings. And—no surprise here—they want to know lots more about what you own offshore. Beginning last year , in 2009. And, if you fail to comply, you could face a $10,000 fine and even prison.
In a recent posting , I wrote how and why a U.S. citizen or long-term resident might want to expatriate; i.e., sever all legal ties and responsibilities to the U.S.
In my last column I recounted a recent sleepless night in which I reviewed President Obama’s revenue proposals for the 2011 budget, in a dense document with the picturesque name of the Greenbook . I focused on the Treasury’s proposals to “Combat Under-Reporting of Income on Accounts and Entities in Offshore Jurisdictions.” And I described these proposals as sort of a root canal, but on your money, not your mouth. Here’s a summary of the remaining proposals in the Greenbook along these lines: “Extend Statute of Limitations for Significant Omission of Income Attributable to Foreign Financial Assets.” This proposal is similar to a provision in H.R.
A judgment creditor can levy upon a debtor’s stock in a corporation. After gaining possession of the stock the creditor can take all the assets of the corporation, such as bank accounts and accounts receivable, and the creditor can close the corporate business. This past week I consulted with a professional who owned his own professional business in the form of a professional corporation; a P.A
A judgment creditor can levy upon a debtor’s stock in a corporation. After gaining possession of the stock the creditor can take all the assets of the corporation, such as bank accounts and accounts receivable, and the creditor can close the corporate business. This past week I consulted with a professional who owned his own professional business in the form of a professional corporation; a P.A
Yes, I know you think it belongs to you. But, Obama and his inside-the-beltway friends know better than you what to do with your money. And, after all, they really need it. You know, with a projected $1.6 trillion deficit and all that. On February 1, the Obamites released their financial fiasco for fiscal year 2011, otherwise known as the proposed federal budget. A key portion of the budget is the revenue proposals, contained in a document referred to as the Greenbook , because—surprise! —It’s printed with a green cover. If you suffer from insomnia, download the Greenbook from the Treasury Web site and spend a few hours looking it over. You’ll save on your Ambien prescription. And, you’ll gain fascinating insights into vital national priorities like the “Inland Waterways Trust Fund.” But I digress. The real point of the Greenbook is to outline how the Obamites’ plans on how they intend to forcibly extract money from you, a concept otherwise know as “taxation.” Think of it as sort of a root canal, but on your money, not your mouth. Since my consulting practice focuses on international tax, I spent a recent sleepless night reading up on the Treasury’s modest proposals to “Combat Under-Reporting of Income on Accounts and Entities in Offshore Jurisdictions.” Here’s a summary—in as plain English as I can muster—of their proposals. “Require Increased Reporting on Certain Foreign Accounts.” Basically, this would impose a 30% tax on many types of U.S-source income to foreign financial institutions (FFIs). The definition of a FFI is very broad, and includes “certain entities engaged primarily in the business of investing, reinvesting, or trading in securities, partnership interests, commodities, or any interests in the foregoing.” In any words, “hedge funds.” And that’s not all. The rules “would be designed so as not to disrupt ordinary and customary market transactions.” Well, of course! H.R.
Often, a high-risk professional will title all assets in the name of their non-professional spouse as an asset protection plan. The professional thinks they are a lawsuit target, but in the event they are sued, they could tell their adversary that they “have nothing in my name.” It’s a simple plan, but it sometimes backfires
If you’re an American, one of the best ways to internationalize your pension or retirement plan is to use it to purchase offshore investments, including offshore real estate. It’s perfectly legal under U.S.
