Category Archives: Tax

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New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important collaboration between the two countries’ tax enforcement efforts.  The TIEA provides a legal framework for the reciprocal and automatic exchange of tax … Continue Reading

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference today President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts.  The announcements come after a month of intense review by the administration following the first release of the so-called Panama Papers, millions of … Continue Reading

Internal Revenue Service Concludes that Fideicomiso or Mexican Land Trusts are not “Trusts” for United States Tax Purposes

On June 6, 2013, the Internal Revenue Service issued Revenue Ruling 2013-14, which concludes that a Fideicomiso or a Mexican Land Trust (MLT) is not taxed as a “trust” for U.S. income tax purposes. While most practitioners have operated on that assumption, it is helpful to have official confirmation from the IRS. Non-Mexican persons are … Continue Reading

Considerations For International Clients Who Intend to Buy A Home In the U.S.

By Amy McEvoy International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with March 2012. According to that survey, the top states in the U.S. for international buyers were Florida, … Continue Reading

IRS Issues Final Regulations Requiring Reporting by Financial Institutions of Interest Payments Made on U.S. Accounts of Non-Resident Individuals

By Keith Gercken and Danica Dodds Summary On April 17, 2012 the Treasury Department and the Internal Revenue Service issued final regulations requiring information reporting by a broad range of banks and other financial institutions of interest paid to certain nonresident alien individuals on funds held in U.S. accounts. These reporting requirements are generally applicable for … Continue Reading
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