2015

FIRPTA Update

Before reading this, please review this previous blog entry – https://htj.tax/2014/10/when-fatca-meets-firpta-some/ An important tax update was made on December 18th.  President Obama, signed H.R. 2029, the tax (the “Protecting Americans from Tax Hikes Act of 2015”) and spending bills (Consolidated Appropriations Act, 2016) to fund the government for its 2016 fiscal year. The December The Act […]

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Singapore Lawyer Convicted and Jailed for Tax Evasion

9 Dec 2015 Ong Cheong Wei, 51, a practising lawyer and former sole-proprietor of law firm Ong Cheong Wei & Co (“OCWC”), was sentenced to 4 weeks in jail for wilfully omitting $306,305.00 in his Income Tax Returns for Years of Assessment (“YAs”) 2007 and 2008, thereby evading income tax amounting to $39,447.26. He was

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Willfulness

So much of the discussion around the IRS amnesty initiatives lies in the concept of “Willfulness”. While nothing here should be construed as legal advice, here are some key points to consider – 31 U.S.C. § 5321 (a)(5)(C)imposes upon any person who “willfully violat[es]” or “willfully caus[es] any violation of … section 5314,” a penalty

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Nonresident Aliens Can Be Subject to the U.S. Estate Tax – But Usually Ignore It

Here’s an article from CNBC’s website dated Nov 4th 2015 –  Aleksandar Stojanov | Getty Images They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign

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Structuring using St Vincent entities

Among the up and coming offshore jurisdictions is St. Vincent and the Grenadines (SVG). At this point in time, the SVG IBC is not required to make public filings or disclosures of its directors, shareholders/members or beneficial owners. The SVG IBC is useful for asset protection, tax planning, or succession planning. SVG also offers international

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Dormant Foreign Corporations and Form 5471 – Rev. Proc. 92-70, 1992-2 C.B. 435

Filing tax returns and forms can be overwhelming. Especially when it comes to foreign companies with substantial US shareholders (US citizens or US greencards). If you want to really go down the rabbit hole, it may be worth having a look at our explanations of “US Persons” from both an immigration and tax perspective –

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