International Tax & Treaties

Introduction To all U.S. citizens, Green Card holders, and certain U.S. residents, if you maintain bank accounts or other financial […]

Introduction Relocating to or from the United States marks a significant life event, but it also introduces considerable complexity from

Introduction For individuals concluding their stay in the United States and returning to Japan, navigating U.S. tax procedures can be

Japanese NISA and iDeCo are Taxable in the US: The PFIC Problem and Risks of Unknowingly Holding Them The complexities

For Japanese companies operating in the United States, intercompany transactions with their parent company are a daily occurrence. However, determining whether the pricing of these transactions is “appropriate” is constantly under strict scrutiny by the U.S. tax authorities (IRS).

Introduction: The Critical Importance of FBAR Reporting and Hidden Risks For U.S. residents, Green Card holders, or U.S. citizens, reporting

The Japan-U.S. Tax Treaty is a crucial mechanism for reducing or exempting withholding tax rates on international income like dividends, interest, and royalties, thereby avoiding double taxation. This article provides a detailed explanation of the treaty’s fundamentals, specific reduced rates, the application conditions of the Limitation on Benefits (LOB) clause, claim procedures, and practical considerations. It offers actionable insights for Japanese individual investors and companies to maximize profits and minimize tax risks from their U.S. investments and transactions.

FBAR/FATCA non-compliance can lead to severe penalties, but the Streamlined Procedures offer crucial relief for unintentional violators. This article comprehensively explains FBAR/FATCA basics, the differences between SDOP and SFOP, how to prove non-willfulness, concrete case studies, pros and cons, common pitfalls, and FAQs, paving the way for compliance. The importance of professional advice is emphasized.

Introduction For J-1 visa holders, including researchers and interns, navigating the complexities of U.S. tax filing can be a daunting