FOREIGN TRUST, ESTATE AND GIFT TAXATION
IWTA provides strategic consulting and assists in selecting and implementing a wealth transfer structure based on clients’ jurisdiction and current needs. We prepare the proper disclosures and tax returns for each circumstance to ensure returns are filed as dictated by U.S. policies and regulations.
It is not uncommon for clients and even their legal advisors to be under-informed in regards to the complex laws and reporting requirements of Foreign Trusts and Foreign Non-Grantor Trusts. What you don’t know can cost you dearly. Click below to learn more about FBAR, required forms and classifying your Foreign Trust.
PRE-IMMIGRATION AND EXPATRIATION PLANNING
IWTA assists clients planning to become U.S. taxpayers as well as those terminating their citizen or green card status. We help mitigate the substantial taxes that can result from these decisions.
If you’re a non-resident alien, have business activities or holdings in the U.S., or just visit a lot, Uncle Sam doesn’t need to wait until you seek permanent status to collect taxes. Lack of understanding of the rules can be costly.
If you’re a U.S. citizen or resident alien that has decided to expatriate,Uncle Sam has a parting gift: exit tax. Expatriation is a complicated affair. Before you make this life-changing decision, be aware of all the rules and consequences. Click below for an overview and learn how IWTA can help.
U.S. REAL ESTATE AND FOREIGN INVESTMENTS
What is FIRPTA and why should you care? The Foreign Investment in Real Property Tax Act (FIRTPA) was passed into law by the U.S.Congress in 1980. Since then, FIRPTA has gone through significant revisions, affecting foreign investors, foreign trusts, gifts, REITS, and more.
For U.S. taxpayers: IWTA provides strategic consulting and tax strategies for foreign investments. For non-U.S. taxpayers: IWTA provides diligent assessment of and planning for investments in U.S. business and real estate.
Click below to get an overview of FIRTPA and how it may apply to your investment situation.
NON-RESIDENT ALIEN TAX PLANNING
Did you know you were being tested? If you are a non-resident alien (NRA), the U.S. government may decide to treat you as a tax-paying resident based on the “alien presence test”. And, even if you fail the “test”, individual U.S. States can impose their own set of criteria.
NRAs and foreign investors need smart strategies and investment structures to minimize U.S. tax exposure. IWTA can help!
Click below to get a better understanding of non-resident alien tax rates and rules.
Lack of foreign financial asset reporting can accrue over time due to erroneous advice, taxpayer oversight or personal issues. The penalties can be severe, even if the assets themselves are modest.
The U.S. federal and state governments have long-standing policies of offering voluntary disclosure programs and initiatives for both individual and business taxpayers. IWTA helps taxpayers navigate that haven’t filed U.S. income tax returns or all appropriate international disclosures navigate the system, file the appropriate documents, and get back in compliance.
Click below for the low down on the Foreign Account Tax Compliance Act (FACTA) and Voluntary Disclosure.
FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA)
If you’re a U.S. citizen with foreign investments, trusts or accounts, thanks to FACTA, which enlists the cooperation of international banks and financial institutions, your holdings have been reported to the IRS. Failure to file the required documents can result in sizeable penalties, even if the investment itself or income gained is negligible. Resident aliens with foreign investments and foreign-owned entities organized under U.S. law are also subject to FACTA reporting.
IWTA helps clients find the right classification for their entities, obtain a Global International Identification Number, and prepare Form W-8 and Form 8965 to ensure compliance.
Click the button below to learn more salient facts about FACTA.
Did you know?: A physical business presence is not necessary for the U.S. government to impose taxes and demand filings of a foreign-held business. State and Local governments are ready to collect as well. Foreign owners of single member LLCs are also subject to reporting requirements — even if the income source is outside of the U.S.
IWTA helps clients establish businesses in the U.S.A., structure them for maximum tax benefits, and file business tax returns as U.S. policies and regulations dictate.
Click the button below for more information on State and Local Tax laws, the Branch Profit Tax, SMLLCs, and how U.S. Estate and Gift Tax and Inheritance Tax for non-U.S. citizens affect business strategy.
FOREIGN ASSETS AND FBAR REPORTING
What constitutes having a financial interest in a foreign account or asset is surprisingly far-reaching, according to the Internal Revenue Service and U.S. tax law. And, citizens are required to report their holdings. Filing applies whether the U.S. citizen lives in country or abroad.
IWTA’s U.S. clients with foreign assets are kept in compliance with the filing of Foreign Bank Account Reports (FBARs). Even small omissions can lead to substantial penalties!
Click the button below to learn more details on FinCEN and FBAR filing.
Get the peace of mind that comes with putting your U.S. business and investment tax affairs in our hands!
Read Expert Tips and Coverage of News & Laws
IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…
Amidst the upheaval of the COVID-19 pandemic, some U.S. taxpayers were unable to file their 2019 or 2020 income tax returns within the IRS’ filing deadlines The Internal Revenue Service, in a show of understanding, fully waived penalties for individual taxpayers and businesses who filed certain late returns by September 30, 2022. Although the deadline has recently passed — and the IRS is not extending it — taxpayers who file late 2019 or 2020 returns may nonetheless be eligible for partial penalty relief, according to the IRS. Provisional grace also applies to taxpayers filing certain international information returns, including Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts; Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)). Read more…
IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Intra-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes
Announced in June, the Joint Strategic Emerging Issues Team, or JSEIT, combines expertise from units across the agency, including Criminal Investigation, Tax Exempt/Government Entities, Large Business & International, and Small Business/ Self Employed.
JSEIT’s goal is to act before a tax scheme becomes a widespread issue. Acting as a conduit between taxpayers with compliance issues and the relevant IRS division, JSEIT hopes to provide early communication to prevent abusive fraud. Any transactions that have already been identified as abusive by the IRS will not be in focus.
￼Jack Brister Featured in Live Event: Estate Planning and Investment Strategies for Multi-Nationals on Oct. 25, 2022
IWTA Founder Jack Brister Featured in Live Event:
Estate Planning and Investment Strategies for Multi-Nationals
New York City, Oct. 25, 2022
Complex Tax and Non-Tax Issues to Be Covered in Depth at Event Produced by European American Chamber of Commerce (EACCNY) on Oct. 25, 2022, 8:30-10:30 a.m. Trust and estate planning and investment strategies for multinationals is a complex topic about which International Wealth Tax Advisors founder Jack Brister has encyclopedic knowledge.
An update on the tax rules and strategies multi-nationals must follow in these areas is the topic of a live event at which IWTA Founder Jack Brister is participating on Tuesday, Oct. 25, 2022. The free event, produced by the European American Chamber of Commerce (EACCNY) takes place from 8:30 to 10:30 a.m. at the New York City headquarters of Offit Kurman.
Frozen: How the Revocation of the U.S. – Russia Tax Treaty Puts Global Trade on Thin Ice
This blog post is an update to IWTA founder Jack Brister’s article published in JD Supra on March 18, 2022, entitled, “Frozen: How the Revocation of the U.S. – Russia Tax Treaty Puts Global Trade on Thin Ice.” The Biden administration is poised to fully block Russia’s ability to pay U.S. bondholders. The Treasury Department told multiple news outlets that it had suspended its tax information exchanges with Russia. Read more…
It Happened in South Dakota
The Pandora Papers, a recent reveal of pervasive cross-border financial crime and elaborately-crafted tax dodging structures, as reported by a global network of investigative journalists, has
already shaken up governments and elections, upended tax authorities and initiated criminal investigations… Perhaps the most intriguing revelation of all from a stateside perspective was the emergence of South Dakota as a preferred tax haven of the rich and famous.
Stage three tax cuts: Albanese government must pass this integrity test
Gilti tax So let me be clear: as North Sydney’s representative, I remain of the position that stage three tax cuts should go ahead in 2024 as planned.The government can afford to keep the legislated stage three tax cuts. What it can’t afford is to let...
Joe Biden: Liz Truss tax cuts a ‘mistake’ and ‘I wasn’t the only one’ who thought so
Tax credits for international students Joe Biden has called Liz Truss’s abandoned UK tax cut plan a “mistake” and said he is worried that other nations’ fiscal policies may hurt the US amid “worldwide inflation”.Biden said it was...
Manitoba needs to pick up the pace on tax relief
What is a foreign trust The province should look to its neighbours and other jurisdictions that are providing meaningful relief In the race to help people struggling with inflation, other jurisdictions are off to a running start. Meanwhile, the government of Manitoba...