The Resource FATCA of the HIRE Act crashes head on into the "twilight zone" (lawful permanent residents living overseas)

FATCA of the HIRE Act crashes head on into the "twilight zone" (lawful permanent residents living overseas)

Label
FATCA of the HIRE Act crashes head on into the "twilight zone" (lawful permanent residents living overseas)
Title
FATCA of the HIRE Act crashes head on into the "twilight zone" (lawful permanent residents living overseas)
Creator
Subject
Language
  • eng
  • eng
Summary
On 18 March 2010, President Obama signed into law the Hiring Incentives to Restore Employment (HIRE) Act. The government "stimulus" dollars in the HIRE Act has its cost and loss of revenues. The lost revenues are expected to be paid in part with the new international tax provisions that were enacted, which are known as part of the Foreign Account Tax Compliance Act (FATCA). These FATCA provisions have broad application and significantly change the rules in a number of international tax areas, which can be summarized as follows: new withholding taxes and new withholding rules applicable to foreign intermediaries and account holders (including financial institutions and certain non-financial institutions such as private hedge funds, private equity investment funds); new tax on foreign trust deemed payments of income (from distributable net income) to settlors, beneficiaries and certain related parties who use foreign trust property (e.g., use of a residential home owned by a foreign trust); new foreign trust reporting rules and additional penalties for failure to file; new reporting of a broadly defined group of foreign assets (with a US$ 50,000 threshold), in addition to the existing informational reporting rules; new reporting requirements for U.S. shareholders in passive foreign investment companies (PFICs); elimination of "portfolio interest" bearer bonds which had previously not been subject to U.S. withholding tax; a new 40-percent penalty imposed on certain understated income amounts (with a low threshold of only $ 5,000) from foreign assets; new tax on "dividend equivalent amount" on certain contracts. This article discusses questions raised by FATCA and its application to lawful permanent residents who are now residing overseas
Citation source
In: International tax journal. - Chicago. - Vol. 36 (2010),
http://library.link/vocab/creatorName
Martin, P.W
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • FATCA
  • resident alien
  • permanent resident
  • worldwide income
  • withholding tax
Label
FATCA of the HIRE Act crashes head on into the "twilight zone" (lawful permanent residents living overseas)
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2010/G-I/ITJ/6_39-44.zip
Publication
Note
20110125

Library Locations

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