Kozusko Harris Duncan

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FATCA documentation for disregarded entities

June 18 2015 The Foreign Account Tax Compliance Act (FATCA) requires entity account holders to document their status for US withholding tax purposes (Chapter 3…

US LLC owned by non-US person has US reporting obligation from calendar year 2017

January 26 2017 Limited liability companies (LLCs) established under the law of a US state are classified by default as disregarded entities if they have only one…

Completing and filing Form 5472 for foreign-owned US LLC

February 1 2018 Beginning in 2018 a limited liability company (LLC) created under the laws of a US state that is wholly owned by a single non-US person (a…

US citizens living abroad still face US tax and reporting obligations

May 4 2017 Particularly since the US presidential election, some US citizens have moved abroad and others are considering such a move. Tax professionals and…

Completing US tax forms: Form SS-4 - Application for Employer Identification Number

December 19 2019 Non-US entities, even when not conducting a business in the United States, must sometimes apply for a US tax identification number, known as an…

Reporting beneficial owners of certain US companies: observations relevant to private client structures

March 11 2021 The Corporate Transparency Act (CTA) became law on 1 January 2021. This article considers aspects of the new act, such as the broad definition of…

Reporting beneficial owners of certain US companies: details of new Corporate Transparency Act

March 4 2021 The Corporate Transparency Act (CTA) recently became law. Once implementation regulations are issued, the CTA will require certain new and existing US…

Overview (January 2021)

January 28 2021 A new administration at the federal government level may mean tax law changes during 2021. Although unlikely to apply retroactively, advisers to…

Estate and gift tax situs of assets - specific examples

December 10 2020 Individuals who are not US citizens and are not domiciled in the United States for transfer tax purposes (non-resident aliens) are subject to US gift…

Estate and gift tax situs of assets - basic rules

December 3 2020 Individuals who are not US citizens and are not domiciled in the United States for transfer tax purposes (non-resident aliens) are subject to US gift…