Treatment of certain foreign currency transactions

Treatment of certain foreign currency transactions

Section 988 of the Internal Revenue Code Treatment of Certain Foreign Currency Transactions taxes certain transactions defined as ‘Section 988 transactions’. The general rule is that the disposition of any non-functional currency will be treated as a section 988...

NZ tax case attracts international attention

A recent NZ court case involved a tax agent (Chatfield & Co), the Commissioner of Inland Revenue (CIR), the Korean National Tax Service and the NZ Competent Authority (Mr Nash). The High Court case of Chatfield and Co vs The CIR challenged the roots of procedural...

Permanent Place of Abode Test

A recent New Zealand court case decided in October is the second one in recent years[1] to go through the courts involving the determination of the permanent place of abode concept (‘PPOA’). In this High Court case, the time bar was opened under Section 108(2) of the...
Why you should file a U.S. tax return

Why you should file a U.S. tax return

Even if your income levels fall below the filing thresholds for U.S. individual income tax returns, it is recommended that a U.S. return still be filed. Filing a tax return starts the statute of limitations running, whilst any year during which a return is not filed...

Troubles with the IRS’s Implementation of FATCA

The National Taxpayer Advocate’s Objectives Report to Congress for Fiscal Year 2016 contained the Taxpayer Advocate’s eleven areas of focus for 2016. Statement Area of Focus #4, The IRS’s Implementation of FATCA Has in Some Cases Imposed Unnecessary...