Cook v. Tait and the U.S. Civil War a bit. See bothSupreme Court’s Decision in Cook vs. Tait and Notification Requirement of Section 7701(a)(50)andThe U.S. Civil War is the Origin of U.S. Citizenship Based Taxation on Worldwide Income for Persons Living Outside the U.S. ***D...
It is also a requirement that active NFFEs have reported less than 50% passive income in the prior reporting period, as well. Governments are considered Active NFFEs. Passive Non-financial Foreign Entities. Passive NFFEs are to active NFFEs what participating FFIs are to nonparticipating FFIs...
In short, BEFORE December 2016, a FATCA/CRS declaration will be obtained for ALL accounts – owned by Residents or Non-Residents. And, It is very critical to understand the CRS/FATCA declaration, which I have explained in my another blog:FATCA / CRS Declaration: Requirement, Importance and D...