FOREIGN INVESTMENTS – Compliance & Disclosure issues

As the national markets grow global, many American investors find themselves with potentially lucrative but highly complicated foreign investment opportunities. While the investments themselves and the returns thereon may be fairly simple and straightforward, the tax treatment of those investments is anything but simple and straightforward. While trying to catch...

California Offshore Voluntary Disclosure – New Voluntary Compliance Initiative for California

In March 2011, California passed legislation to allow a program similar to the federal 2011 Offshore Voluntary Disclosure Initiative (OVDI). Senate Bill 86 was passed by the California legislature, signed by Governor Brown, and entered into California law.  While SB 86 amends several sections of the Revenue and Taxation Code,...

Passive Foreign Investment Companies and Tax Treatment – Understanding PFIC reporting

With the heightened interest in U.S. connected people and businesses in offshore banking, it is important to understand the importance of properly to the Internal Revenue Service and various State taxing agencies of foreign bank accounts and investments. The Federal income tax rules regarding those who have interest in any...