Duncan Teed

Flowchart: What is a “tax-favored foreign retirement trust” per §6048 regulations ?

3520, Pensions, Trusts / By /

The below flowchart helps you determine if a foreign retirement account may qualify as a tax-favored foreign retirement trust; of course, this is not intended to be legal nor tax advice. This flowchart expands upon the article written for Bloomberg’s Tax Management International Journal by Arielle Tucker and myself, you my find the article here …

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FinCEN’s New Foreign Pooled Investment Vehicle Rule: Understanding the Reporting Requirements

CTA / By /

Background refresher on the Corporate Transparency Act: What is the CTA? – Tax Logicians   The CTA imposes specific reporting requirements on entities formed under the laws of foreign (non-US) countries that would otherwise qualify for reporting exemptions (as many US investment entities will be exempt). Let’s delve into the key aspects of this regulation …

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Non-US Pensions Trusts and Form 3520

3520, Pensions, Trusts / By /

Form 3520 Unveiled Form 3520, also referred to as the “Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts,” serves as the IRS’s instrument for eliciting information regarding financial interactions involving foreign trusts or gifts. It operates primarily as a disclosure mechanism, with no direct tax implications. Pension Trusts and …

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FATCA: A Layman’s Guide to Foreign Account Tax Compliance Act

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Let’s embark on a journey to demystify the Foreign Account Tax Compliance Act (FATCA). We’ll break down this complex piece of tax legislation into digestible bits. One thing to keep in mind at the start, FATCA is different than the FBAR; some individuals may have to comply with both disclosure regimes and there is some …

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What is the CTA?

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What is the CTA? The Corporate Transparency Act (“CTA”) is a new US law intended to expand existing US anti-money laundering enforcement.     The CTA requires the disclosure of the ultimate Beneficial Owners of all US business entities, such as corporations, certain LLCs, certain trusts, and other corporate type entities which are deemed Reporting …

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