FOREIGN PROPERTY HOLDINGS (PG. 393-412) Flashcards
UNITED STATES PERSON
See pg. 395
FOREIGN PERSON
See pg. 395
ALIEN
An individual who is not a US citizen or US national
US CITIZEN
See pg. 396
US NATIONAL
An individual who owes his/her sole allegiance to the US, including all US citizens, along with some individuals who are not US citizens
GREEN CARD HOLDER
Someone who is considered a permanent resident
GREEN CARD TEST
The process of determining whether an individual who is resident, for US federal tax purposes, is a lawful permanent resident of the US at any time during the calendar year
LAWFUL PERMANENT RESIDENT OF THE US
An individual, at any time, who has been given the privilege of residing permanently in the US as an immigrant
SUBSTANTIAL PRESENCE TEST
See pg. 397/398
CLOSER CONNECTION
An exception for the substantial presence test (see pg. 399/400)
FOREIGN BANK AND ACCOUNTS REPORT (FBAR)
A report that must be filed by a US person, citizen, resident, corporation, partnership, limited liability company, trust and estate, of a financial interest in or signature or other authority over at least one financial account located outside the US, if the aggregate value of the foreign financial accounts exceed $ 10,000 at any time during the calendar year
US SHAREHOLDER
A US person who owns directly, indirectly, or constructively 10% or more of the total combined voting power of all classes of stock entitled to vote in a foreign corporation
CONTROLLED FOREIGN CORPORATION (CFC)
Any foreign (non-US) corporation where more than 50% of the voting power or more than 50% of the total value of the stock is owned directly or indirectly by a US shareholder, at any point dureing the corporation’s taxation year
PASSIVE FOREIGN INVESTMENT COMPANY (PFIC)
A foreign (non-US) corporation, where morethan 75% of its gross income is passive income or at least 50% of the corporation’s average pecentage of assets held during the tax year produce passive income
FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA)
A US act that requires foreign (non-US) financial instituions and certain other non-financial foreign entities to report foreign assets held by their account holders who are US taxpayers