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Has the CTA been over-ruled ?

The recent (March 1, 2024) US court ruling[i] in federal district court deemed the Corporate Transparency Act (“CTA”) unconstitutional.   FinCEN subsequently (March 4, 2024) stated it will not require compliance with the CTA for the plaintiffs in the case; the plaintiffs generally being members of the (US) National Small Business Association (“NSBA. On March …

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The new Corporate Transparency Act & Foreign Trusts

Watch out latest video for a short (13  minute) overview of how the CTA can interact with foreign trust structures which invest into the United states.  This link goes to the Youtube version of the video:  Tax Logicians Trusts and the CTA Nov 8 2023 – YouTube     If you want a refresher on the …

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Form 5472 Requirements for Single Member LLC Owned by a Non-US Person

Let’s unravel the IRS’s Form 5472 requirements in the context of a single member LLC owned by a non-US person. Form 5472 Demystified Form 5472, officially titled the “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” is your IRS tool to spill the beans …

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Fifteen Fun Acronyms & Terms

The world of US tax and disclosure compliance is filled with a mess of acronyms and initialisms; here is a short glossary to help find your way. 1. FBAR (Foreign Bank Account Report) The FBAR, also known as FinCEN Form 114, is a report filed with the Financial Crimes Enforcement Network (FinCEN) of the U.S. …

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