Foodman CPAs and Advisors

Beware of Sales or Transfers of 10% ownership in a Foreign Corporation

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Beware of Sales or Transfers of 10% ownership in a Foreign Corporation – JD Supra. The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign corporations. In order to accompany […]

Did you know that the “Act” has a Deduction for Dividends Received (DRD)?

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Did you know that the “Act” has a Deduction for Dividends Received (DRD)? – JD Supra. The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system.  Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore.  In the transition […]

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

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U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax” – JD Supra. The “Tax Cuts and Jobs Act” (the “Act”) has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”.  This mandatory “transition tax” or “repatriating charge” is […]

Conflict of Interest: When professional judgement is compromised….

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Conflict of Interest: When professional judgement is compromised…. JD Supra. Conflicts of interest can arise at any time during a professional engagement.  According to the American Institute of Certified Public Accountants (AICPA),  “A conflict of interest may occur if a member performs a professional service for a client or employer and the member or his […]

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

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BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)? – JD Supra. There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities.   The U.S. Government is determined to enforce financial transparency and combat the misuse […]

Will the question for the Year 2017 be: Do you have Foreign Financial Accounts?

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Will the question for the Year 2017 be: Do you have Foreign Financial Accounts? – Foodman CPAs & Advisors Since the Global Financial Crisis that began in 2007, domestic and international Taxpayers have been under increasing scrutiny. The financial system has been heavily regulated and closely monitored. In addition, the US Tax Gap (amount of […]

Why are US Citizens Renouncing their Citizenship?

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Why are US Citizens Renouncing their Citizenship? – JD Supra. A significant number of US Taxpayers living overseas have become “unbankable” where they live because of  high account servicing costs  for local banks (Foreign Financial Institutions – also known as FFIs) caused by the requirements of FATCA.  A number of FFIs will not open bank […]

Bitcoins and the IRS: Reporting and Storing

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Bitcoins and the IRS: Reporting and Storing – JD Supra. Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that function in the same manner as Bitcoin and […]