The PFIC regime has been in existence since 1986. Introduced in the Tax Reform Act, the regime closed a loophole. Prior to the change, assets could be transferred to entities organized outside the U.S., in order to escape U.S. taxation. As with other foreign...
The Tax Court case of Virginia-based taxpayers Toso & Salman tested several US tax principles which affect all US citizens and residents[1]. Those principles include the statute of limitations, the definition of ‘gross income’, and the ability to offset...
Now that we are on the cusp of the fourth quarter of 2015 it is time to start thinking about tax planning before the tax year closes out – taking with it an opportunity to minimize your U.S. income taxes. PFICs and how they work If you have investments,...
If you’re a US citizen, now is the hour to ensure that you are reporting your KiwiSaver funds correctly. Firstly, let’s define what a KiwiSaver fund actually is. A KiwiSaver fund is a voluntary retirement fund which may be set up by anyone including employees,...
