U.S. Taxation of Entities, Associations, and Partnerships: What’s Your “Situs” Roger?
In the U.S. tax system, there is no characteristic of associations or entities (partnerships, corporations, and trusts) that corresponds exactly to the “nationality” or “residence” of individuals. For most organizations, however, there is a place – or at least a distinct legal environment – that establishes their existence and identity. This place, sometimes referred to […]
Understanding the Source of Income Rules – Part I
This blog is a primer on the source of interest rules. It is a four-part series. Let’s begin with some basics. The U.S. taxes U.S. persons on their worldwide income. Why are the source of interest rules important? Because sourcing can have a significant effect on the computation of a U.S. person’s foreign tax credit […]
Examining The Section 911(d)(3) “Foreign” Tax Home Requirement
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How to Apply to the Offshore Voluntary Disclosure Program
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Offshore Voluntary Disclosure Program: The Survivor’s Manual
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What does it mean for the taxpayer to have “signature authority” over a foreign financial account?
A person has a “financial interest” in a foreign account not only if he is the owner of record or holder of legal title, but also if he has signatory authority of the account or maintains it jointly with another person. Signature authority is the authority of an individual to control the disposition of assets […]
What Does A Financial Account Include For FBAR-Reporting Purposes?
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What does it mean for the taxpayer to have a “financial interest” in a foreign account?
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The Rules Governing Taxation of Foreign Nationals
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Walking The Sawdust Trail
Those who responded to the altar call after one of Billy Sunday’s sermons were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer. Before he became a travelling evangelist, and possibly even before he became a […]