FOREIGN PROPERTY HOLDINGS (PG. 393-412) Flashcards

1
Q

UNITED STATES PERSON

A

See pg. 395

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2
Q

FOREIGN PERSON

A

See pg. 395

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3
Q

ALIEN

A

An individual who is not a US citizen or US national

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4
Q

US CITIZEN

A

See pg. 396

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5
Q

US NATIONAL

A

An individual who owes his/her sole allegiance to the US, including all US citizens, along with some individuals who are not US citizens

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6
Q

GREEN CARD HOLDER

A

Someone who is considered a permanent resident

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7
Q

GREEN CARD TEST

A

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

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8
Q

LAWFUL PERMANENT RESIDENT OF THE US

A

An individual, at any time, who has been given the privilege of residing permanently in the US as an immigrant

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9
Q

SUBSTANTIAL PRESENCE TEST

A

See pg. 397/398

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10
Q

CLOSER CONNECTION

A

An exception for the substantial presence test (see pg. 399/400)

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11
Q

FOREIGN BANK AND ACCOUNTS REPORT (FBAR)

A

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

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12
Q

US SHAREHOLDER

A

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

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13
Q

CONTROLLED FOREIGN CORPORATION (CFC)

A

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

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14
Q

PASSIVE FOREIGN INVESTMENT COMPANY (PFIC)

A

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

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15
Q

FOREIGN ACCOUNT TAX COMPLIANCE ACT (FATCA)

A

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

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16
Q

NON-RESIDENT ALIEN

A

An individual who is not a resident or citizen of the US and does not hold a US green card