International U.S. Tax Compliance Global Reach & Transparency - - PowerPoint PPT Presentation

International U.S. Tax Compliance

Global Reach & Transparency

Pierre Saliba

CEO Foodman CPAs & Advisors

Pierre Saliba, an experienced accountant with more than 20 years in public and private accounting, focuses on a broad spectrum of industries, including healthcare, manufacturing and not-for-profit organizations. He joined the firm in 2002. Prior to that, Mr. Saliba worked internationally in the garment industry as a cost accountant and production manager from 1986-1991. Upon returning to the United States in 1992, he continued in the garment industry as a controller and production manager. During his college years, he worked as an intern for the Internal Revenue Service in New York City, the Controller’s Office of the City of New York and Seagram & Sons. Mr. Saliba graduated from Baruch College in 1985 with a Bachelor’s degree in Business Administration, and is fluent in French and Creole and proficient in Spanish. He is chairman of the Haitian-American Chamber of Commerce of Florida, the largest Haitian-American chamber in the nation. He is also an active member of other Miami civic and charitable organizations, offering both time and resources to helping those in need..

T: 1(305) 365-1111 E: pierre@foodmanpa.com

Historically

➔ Unique amongst other global economies ➔ Relies on self reporting ➔ Willful Tax Evasion is a criminal offence and subject to penalties and incarceration ➔ US tax payers with foreign accounts of over USD 10,000 must file FBAR along with their tax return (other forms)

U.S. Extra-Territorial Tax Collector

Who is a U.S. Tax Payer

➔ U.S. Passport Holder ➔ Green Card Holder / Permanent Resident ➔ Pass the substantial Presence Test

• 183 days in one year
• Average of 122 days in last three years

➔ Includes Dual Citizens:

• Children born in U.S. of Non U.S. parents
• Children born outside the U.S. of U.S. parents

➔ Citizenship Renunciation

How does this Affect You?

What is Changing?

➔ Global Trend for Transparency ➔ OECD (Organization for Economic Cooperation and Development)

• 99 Countries sign Tax Information Exchange Treaties
• Over 800 Treaties signed

➔ Willful Tax Evasion continues to be a criminal offence; penalties and sentences are getting stricter and now being considered if it should be the same category of crime as Money Laundering ➔ US tax payers with foreign accounts of over USD 10,000 must continue to file FBAR along with their tax return and now you also have to file FORM 8938 for any foreign assets over $50,000. (other forms) ➔ FATCA

U.S. Extra-Territorial Tax Collector

➔ Foreign Account Tax Compliance Act ➔ Signed into Law – March 2010 ➔ Deputizes Countries (FATCA Partners) and Financial Institutions World Wide to report and withhold on all accounts and structures where U.S taxpayers are beneficial owners. ➔ IRS agents abroad increased ➔ Reporting to IRS of U.S. Accounts starts in March 2015 for all activity (including account closures) in 2013 and 2014

What is FATCA?

➔ New IRS Agents abroad ➔ Additional Information from:

• OECD Tax Treaties
• Whistleblower Program
• FATCA
• E-Trak System Accumulating IRS Intelligence / Social Media

New IRS Information Tools

Options for Individuals

➔ Continue as present ➔ Amend past returns if necessary ➔ Quiet Filing ➔ Streamlined Filing for Low Risk Compliance ➔ OVDP ➔ Comply and Citizen Renunciation

Obligations / Options

Important Considerations

➔ Consult with US Licensed Attorney and CPA (OVDP Expertise) ➔ Do not use advisors who assisted you while not in compliance ➔ If you decide to disclose it has to be 100% ➔ Do not shoot the messenger

Thank You

Questions