By now we have all heard about Tuesday’s court decisions regarding the subsidy issue of the Affordable Care Act (ACA, or “Obamacare”). The U.S. Court of Appeals for the D.C. Circuit ruled 2-1 in Halbig v. Burwell that the subsidies may not be paid in States where the Federal Government operates a health care Exchange. ... [Read more]
The Foreign Account Tax Compliance Act (FATCA), which has recently come in to force, applies to any person or entity described as a U.S. person. There is some ambiguity as to who may actually be a U.S. person. For instance, would the non-U.S. spouse of a U.S. citizen living abroad be subject to FATCA’s provisions? ... [Read more]
The United States Export-Import Bank (EXIM) faces closure after September 30, 2014 unless Congress chooses to reauthorize the Bank’s charter. EXIM provides loans and loan guarantees to support U.S. companies who export goods abroad. The reason for the Bank’s existence is to promote U.S. exports, place U.S. exporters on an equal footing with foreign competitors, ... [Read more]
The Foreign Account Tax Compliance Act (FATCA) becomes fully effective on July 1, 2014. The Internal Revenue Service (IRS) has announced a number of changes to the former Offshore Voluntary Disclosure Program (OVDP) as well as FATCA enforcement that impacts U.S. taxpayers with foreign assets. The major changes taxpayers should be aware of are on ... [Read more]
FATCA mandates that U.S. banks making payments to foreign banks that do not have a data sharing agreement with the U.S. are required to withhold 30% of the payment. The withholding requirement is, theoretically, designed to ensure compliance with U.S. taxes. A number of countries have signed on to FATCA (meaning the 30% withholding doesn’t ... [Read more]