Table of Contents
Superannuation (Super)
→ Need to decide content outline
Various references to leave in or draw from
- Roy Berg et al paper on Superannuation(broken link - article was published in TaxNotes International, vol 84 No 2, Oct 10, 2016, p. 177)pdf
Resources
Brager Tax Law requested documents from the IRS under FOIA. Here is what they found:
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- Advanced Technical Training for Revenue Officers - Abusive Tax Schemes
- LB&I International Individual Compliance
- Offshore Collection Techniques for ATAT ROs
- Global Collection Issues
- Redacted - Offshore Course 31629
- SBSE ADV Tech 2 Binder
- CPE Topics Binder
→ I've downloaded all of the documents - just need time to upload and link here so that we have access even if Brager's site is taken down. ~Karen
Relevant Documents
Tax Court vs Dixon is an ongoing US tax court case between an Australian resident US Person and IRS. This case is scheduled to go to court in late Sept 2020. Amongst other things, this case is worth monitoring as the IRS has reserved the right to rule on the taxation of Australian Super. If they do this, it may be the first official IRS position on US taxation of Australian Superannuation.
Tax Court case Dixon vs US:
Articles in SMSF Adviser:
- https://www.smsfadviser.com/news/18640-dixon-super-claim-dismissed-by-us-court (Court of Claims case dismissed, not Tax Court case)