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IRS Streamlined Offshore Voluntary Disclosure Program (OVDP)

9 Q&A’s About The IRS Streamlined Offshore Voluntary Disclosure Program

The IRS Streamlined Procedures Q&A’s There are many legitimate reasons United States persons may maintain foreign bank accounts or foreign assets. Perhaps an individual owns real estate in a foreign country, making payments via a foreign bank account easier. Alternatively, an individual has come to the United States for education and remained or married a […]

What U.S. Citizens Should Know About Form 5471 (2)

What U.S. Taxpayers Should Know About Form 5471

What Is Form 5471?  The title of Form 5471 lays it out succinctly, “Information Return of U.S. Persons Concerning Certain Foreign Corporations.”  It is the form used to report information about a foreign corporation where a US person owns an interest in the said foreign corporation. It sounds simple enough…. A taxpayer or tax practitioner […]

Forward Triangular Merger

Forward Triangular Merger

As discussed previously in other articles, reorganizations can provide a way to restructure business entities or acquire others without experiencing high tax costs. In other words, reorganizations offer ways to accomplish business goals through tax-free restructuring like a forward triangular merger. Common Use for a Forward Triangular Merger One standard method used is a forward triangular merger, or […]

Non-Recourse Liability and Debt

Non-Recourse Liability and Debt

Advantages of Taking on Debt with Non-Recourse Liability Non-recourse debt means that if the debtor defaults, the creditor cannot pursue the debtor personally. Instead, the creditor must seek recovery from the collateral securing the loan. The creditor can file a suit against the borrower if the collateral does not cover the debt. However, if the […]

Important Information About B Reorganizations

Important Information About B Reorganizations

What are Reorganizations? A reorganization allows a company to restructure its operations without triggering significant tax consequences. A reorganization is generally considered a change in the form of a corporation rather than a mere change in the place of doing business. For example, suppose a company moves its headquarters from New York City to Los […]

What is FIRPTA Withholding

What is FIRPTA Withholding?

FIRPTA, which stands for the Foreign Invest Real Property Tax Act, authorizes the United States government to tax foreign persons on the disposition of real property. The article below has been prepared by a Denver tax attorney to provide information related to FIRPTA. What is FIRPTA? If you are considered a foreign person for tax […]

Do You Know About IRC 368 Tax-Free Reorganization

Do You Know About IRC 368 Tax-Free Reorganization?

IRC Tax-Free Reorganization Reorganization is a term used when a company changes its structure. A reorganization differs from a merger or acquisition because it does not involve merging two companies. Instead, it consists in changing the legal form of a corporation. Reorganization is also different from liquidating a company because it doesn’t involve selling all […]