美国税务人员的定义是什么?

One of the first questions posed to us by local advisors (investment managers, 律师事务所, 会计师事务所, 受托人)和他们的客户, 在税务方面，美国人的定义是什么?

The US tax system imposes its income tax on “US Persons”; and the tax reaches all forms of income and gains whether US-sourced or arising outside the US.

The concept of a US Person includes individuals, corporations, partnerships, trusts, and estates.

个人: Citizens, 绿卡持有者 and those individuals that meet the US residency tests.
Citizens include individuals born in the United States and in many cases individuals born outside the US with at least one US parent.

绿卡持有者 are individuals who have been granted permanent right to reside in the US as long as they comply with any restrictions imposed on the grant.

给绿卡持有者的警告

Your tax responsibilities as a Green Card holder do not change if you are absent from the US for any period of time. Your income tax filing requirement and possible obligation to pay US taxes continue until you either surrender your Green Card or there has been a final administrative or judicial determination that your Green Card has been revoked or abandoned. 因此, even if the US Citizenship and Immigration Service (USCIS) no longer recognizes the validity of your Green Card because you have been absent from the United States for a certain period of time or the Green Card is 更多的 than ten years old, you must continue to file tax returns until there has been a final determination that is not subject to appeal that your Green Card has been revoked or abandoned.”

美国居民 个人是否符合实质存在测试. (一个为期三年的天数计数测试.)

实体: 公司 and partnerships formed under US (state) law; Trusts that meet a combination “US court” and “US control” test (regardless of the legal jurisdiction in which they are formed); and Estates (based on a “facts and circumstances” test that looks at the residence of the executor and the location of a majority of the assets.

Failure to file the income tax return timely or with an understatement of income will generally result in a penalty being imposed. The penalty is generally based on the amount of the taxpayer’s tax liability.

除了每年的所得税申报表, all taxpayers (individuals and entities) are faced with a substantial number of “informational returns”. These returns relate to a taxpayer’s interest in all things “foreign”, e.g. 外国金融账户和资产, 外国公司, 外国合作伙伴, 外国信托. Failure to file these forms timely or with incorrect information can result in the imposition of large penalties, 通常10美元起,000.

国税局会怎么找到我?

“躲避”国税局越来越难了. 随着《澳门新葡新京官方》(新法)于2010年被美国外资金融机构通过, 包括外国受托人, 必须向美国国税局报告其美国账户持有人吗. Further, individuals who have come forward under one of the various “自愿披露” programs have often had to identify US persons with whom they have contacts.

Information is also shared between the US and its numerous treaty partners. Finally, individuals can be paid large sums to act as “whistle-blowers”.

通过我们的 美国扩张实践, we see founders or staff members who start commuting back and forth to the US to promote or start their business, 没有意识到, they often cross the threshold of residency (substantial presence test). Residency means you are taxed on worldwide income and have reporting obligations. 没有适当的计划, inadvertently subjecting your worldwide assets and income to the US tax system may have serious consequences.

概述:
个人

• 出生在美国
• 在美国以外出生，父母为美国人
• 归化的公民
• 绿卡持有者
• 税收居民

实体

• 根据美国(州)法律成立的公司
• 根据美国(州)法律成立的合伙企业
• Trusts regardless of where formed if they meet the “US Court” and “US Control” tests
• 遗产:美国遗嘱执行人和资产

澳门官方老葡京 如果你有任何问题.

本文作者:大卫·米. 戴利