Foreign Income Archives - John R. Dundon II, Enrolled Agent

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Foreign Income

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18 Jul Foreign Bank Account Reporting (FBAR) – FinCEN Form 114

Posted at 00:00h in FBAR, Asset Classification, Foreign Income, Foreign Investment, Immigrant

Foreign Bank Account Reporting (FBAR) -FinCEN Form 114 FinCEN Financial Crimes Enforcement Network (FinCEN) is abureau of the Treasury Department.Authorized under the Bank Secrecy Act, foreign bank account reporting commonly referred to as "FBAR" is electronically reported to the IRS via FinCen Form 114 separate and...

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14 Jul Lessons Learned Preparing & Defending IRS Form 8938 – FATCA

Posted at 00:00h in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax, Tax Treaties

Foreign Financial Asset Reporting (FATCA) -Form 8938 was enacted March 18, 2010 and requires filing of Form 8938.The FATCA requirement does not replace or otherwise affect a taxpayer's obligation to file an FinCEN Form 114.Basically if you are a US taxpayer holding foreign financial assets you...

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27 Jun Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116

Posted at 00:00h in Foreign Tax Credit, Alien, Foreign Income, Foreign Investment, FTC, International Tax, Tax Credit, Tax Guidance & Preparation

Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116. With all the political rhetoric about borders and boundaries circulating these days by 'news media' outletsthe fact of the matter is US Taxpayers are increasingly working and living abroad everyday. With that taxpayers and tax...

16 Jun Foreign Earned Income Exclusion (FEIE): Drill Down into IRS Form 2555

Posted at 00:00h in International Tax, FATCA, FBAR, Foreign Income, Foreign Investment

Living and working outside of the USA - anyone can do it - everyone should....

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27 Apr Top International Tax Questions Answered

Posted at 00:00h in International Tax, Alien, Foreign Income, Foreign Investment

Fear NOT the US Tax Code - it is but a paper tiger. All are welcome!...

21 Oct Different Sources of Income Matter FDAP v. ECI

Posted at 00:00h in Alien, Alimony, Distributions, Expatriation, Foreign Income, Foreign Investment, International Tax, Paying Taxes

Different Sources of Income Matter FDAP v. ECI One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any regard to where the income is...

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05 Oct IRS Form 8833 – Treaty-Based Return Disclosure Under IRC 6114

Posted at 00:00h in Foreign Income, Foreign Investment, International Tax, Tax Treaties

IRS Form 8833 - Treaty-Based Return Disclosure Under IRC 6114 - When MUST It Be Filed? While the light of my life was off at a family wedding in Fargo, ND this past weekend a friend flew into town unexpectedly from Minnesota with a complimentary ticket...

22 Sep Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

Posted at 00:00h in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing

In Coca Cola's SEC 8-K filinglast week we learned thatthe IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09.This is very BIGwhen it comes to enforcement ofIRC...

11 Aug Foreign Investment in Real Property Tax Act and Your TIN – IRC 897, 1445; TD 9082; IRS Form 8882, W-7

Posted at 00:00h in 1031 Exchange, Asset valuation, FIRPTA, Foreign Income, Foreign Investment, Immigrant, ITIN

As part of an IRS Examination under the Foreign Investment in Real Property Tax Act (FIRPTA) you absolutely must have a Taxpayer Identification Number (TIN) to mitigate26 U.S. Code Â§ 1445 - Withholding of tax on dispositions of United States real property interests If youdo not...

23 Jul Exceptions to the requirement that a U.S. Federal Income Tax Return Accompany an ITIN Application – IRS Form W-7

Posted at 00:00h in Foreign Income, ITIN, Taxpayer Identification Number

You canindeedclaim an exception to the requirement to submit an original U.S. Federal income tax return with IRS Form W-7 - ITIN Application, all you need is substantiated proof of your claim. So what are the exceptions allowing for the ITIN application without a tax return...