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Kozusko Harris Duncan | USA | 23 Sep 2021

Court upholds higher IRS penalty on late filing of Forms 3520 and 3520-A

The estate of a deceased US taxpayer recently lost its argument that the Internal Revenue Service (IRS) should have assessed only the 5% penalty levied on US owners who fail to ensure that their foreign trust files an annual return in a timely manner. The IRS assessed a penalty because both Form 3520, Annual Return to Report Transactions with Foreign Trusts, and Form 3520-A, Annual......
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Kozusko Harris Duncan | USA | 2 Sep 2021

Changing times: tax and reporting requirements for US citizens and Green Card holders moving abroad

For various reasons, some US citizens and Green Card holders are considering living abroad. How tax professionals and trust officers worldwide advise these individuals depends on their objectives. Does the individual want to live in another country for a limited number of years or to change domicile and resettle permanently? Will the individual be working abroad or living off savings and......
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Kozusko Harris Duncan | USA | 11 Mar 2021

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

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 'beneficial owner' when applied to trusts, privacy concerns and further compliance responsibilities that may be of interest in the context of family succession planning structures that include entities established under the laws of a US state.
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Kozusko Harris Duncan | USA | 4 Mar 2021

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

The Corporate Transparency Act (CTA) recently became law. Once implementation regulations are issued, the CTA will require certain new and existing US companies to disclose information about their beneficial owners. There are both civil and criminal penalties for violations of CTA requirements. Given that family succession planning structures may include entities established under the laws of......
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Kozusko Harris Duncan | USA | 28 Jan 2021

Overview (January 2021)

A new administration at the federal government level may mean tax law changes during 2021. Although unlikely to apply retroactively, advisers to international families should keep an eye on US tax developments, including increased information reporting. This overview provides a summary of the general framework for US gift, estate and generation-skipping transfer taxes and describes some of......
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Kozusko Harris Duncan | USA | 10 Dec 2020

Estate and gift tax situs of assets – specific examples

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 tax only on gifts of real property and tangible personal property located in the United States. On death, a significantly broader list of property is subject to US estate tax. This article provides examples of certain specific assets that are......
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Kozusko Harris Duncan | USA | 3 Dec 2020

Estate and gift tax situs of assets – basic rules

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 tax only on gifts of real property and tangible personal property located in the United States. On death, a significantly broader list of property is subject to US estate tax. Advisers to families with international investments should......
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Kozusko Harris Duncan | USA | 3 Sep 2020

US individuals investing in foreign companies should consider a Section 962 election to reduce the GILTI tax burden

The Section 962 election has become one of the most common planning tools for tax professionals over the past couple of years. However, it is important to keep in mind that each situation is different. With variables ranging from projected actual future distributions to local country tax rates, it is always important to consider making a Section 962 election among other planning alternatives,......
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Kozusko Harris Duncan | USA | 18 Jun 2020

Completing US tax forms: Form 5472 – foreign-owned disregarded entities

A limited liability company (LLC) that is created under the laws of a US state and wholly owned by a single non-US person is required to report transactions with its non-US owner and other related parties to the Internal Revenue Service (IRS) on Form 5472, which must be submitted with a pro forma Form 1120. In response to the COVID-19 outbreak, the IRS has automatically extended the filing......
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Kozusko Harris Duncan | USA | 23 Apr 2020

Time again to file Bureau of Economic Analysis survey Form BE-10 to report investments abroad

Using Form BE-10, the Bureau of Economic Analysis (BEA) conducts a survey on US direct investment abroad. The survey is conducted every five years and currently covers fiscal years ending in 2019. The gathered data is used to produce statistics on the scale and effects of US-owned business activities abroad. All US persons subject to the reporting requirements must file, even if they are not......
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