FATCA Is Officially Underway
We’ve been talking about it for months and according to the IRS, FATCA is now officially underway. The Foreign Account Tax Compliance Act is live and the IRS is actively exchanging information with several other countries that have signed on. So what does that mean for you and your information if you have funds in a foreign bank account? Is your information now subject to the IRS?
According to the nation’s top tax agency, at this time it is only sharing information in reciprocal exchanges that meet the agency’s strict requirements and security standards. FATCA was first passed in 2010, but most of the law didn’t take effect until this year. Any foreign institution that doesn’t comply stands to be frozen out of the all-important U.S. markets. In other words, compliance really isn’t an option.
The IRS is now offering a searchable financial institution list, as well as a downloadable tool, plus a user guide. All foreign financial institutions that have signed up with FATCA have to disclose names, addresses, account numbers and information and U.S. ID numbers. Taxpayers also need to be aware that reporting their foreign account information with FATCA is not enough. They must still file their FBARs, and a Form 8938 might also be necessary.
Make sure you don’t overlook these forms or you will wind up paying penalties: civil and possibly criminal. Sometimes the civil penalties, or the financial fines, could actually exceed the amount in your foreign account. While FATCA is really just getting started, you better not wait to get in compliance. GROCO can help you prepare for FATCA, as well as with your FBARs and your Form 8938. Click here to contact us or call us at 1-877-CPA-2006.
Details of Patterns of Reorganization
Details of Patterns of Reorganization • “A” Reorganization • “B” Reorganization • “C” Reorganization • “D” Reorganization • “E” Reorganization • “F” Reorganization • “G” Reorganization “A” Reorganization Type “A” Reorganization consists of • Merger • Consolidation Both involve the acquisition of one company’s assets by another. Merger Explanation: • Target transfers its assets and…
“B” Reorganization
“B” Reorganization Type “B” involves the acquisition of stock of one corporation by another, and the target corporation becomes a subsidiary of the acquiring, as a result. Requirements of “B” Reorganization 1) The acquisition must be one of a series of acquisitions that are part of an overall plan to acquire the requisite control. 2)…
“C” Reorganization
“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…
“D” Reorganization
“D” reorganization: “Spin-off” and “Split-off” acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…