Posts Tagged ‘tax treaty’

Automatic information exchange will doom the secrecy strategy

Posted on May 26, 2009, 8:00 pm, by Phil, under 2009 FBAR Amnesty, International tax audits and enforcement.

U.S. residents with secret bank accounts outside of the United States rely on some weak strategies to keep themselves out of trouble. “How will the IRS ever find out?” is what I hear again and again. The truth will come out. Maybe not now. But eventually. Here’s a bullet, headed straight at you. It may [...]

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Sarkisov v. United States: when are you a "grant recipient" under a tax treaty?

Posted on February 2, 2005, 8:39 am, by Phil, under International tax audits and enforcement.

Here’s a recent case out of the U.S. Court of Claims. A Russian was hired by the University of Nevada to do research, and was present in the U.S. under a J-1 visa. He claimed to be exempt from U.S. income tax under the U.S./Russia income tax treaty. The treaty says that if you are [...]

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