Understanding the “GILTI” of the Tax Reform
Understanding the “GILTI” of the Tax Reform – JD Supra 3/27/18. The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code. One of them is the tax on Global Intangible Low-Taxed Income (GILTI). Beginning with January 2018, a U.S. shareholder of any Controlled Foreign […]
IRS Virtual Currency Amnesty? Not so Fast!
IRS Virtual Currency Amnesty? Not so Fast! – DBR 3/22/18.
IRS and Accuracy
IRS and Accuracy – JD Supra 3/21/18. According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and regulations that cause an underpayment of a required tax. The amount of an […]
Changes in Alimony for Payer Spouse and Recipient Spouse under Tax Reform
Changes in Alimony for Payer Spouse and Recipient Spouse under Tax Reform – JD Supra. Since the early 1940’s, alimony payments have been tax deductible for the Payer Spouse. The recipient of the alimony (Recipient Spouse) paid the income tax on the alimony payments. The Tax Cuts and Jobs Act (TCJA) puts an end to […]
Shareholders of S Corps can defer payment of Transition Tax
Shareholders of S Corps can defer payment of Transition Tax – JD Supra. The Tax Cuts and Jobs Act (TCJA) includes 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” regardless of whether earnings have actually been […]
Registration of Beneficial Owners: COMING TO YOU SOON?
Registration of Beneficial Owners: COMING TO YOU SOON? – JD Supra There is a new Bill drafted on November 14, 2017 called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill is currently in a committee in the Senate and it proposes a substantial overhaul to the Bank Secrecy Act (BSA). Section 9 of […]
No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers
No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers – JD Supra. The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. One of the […]
FBARs 101
FBARs 101 – JD Supra. US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000 at any time during the calendar year, must file FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) – a/k/a […]
The IRS is on to Crypto
The IRS is on to Crypto – JD Supra. The IRS Chief of Criminal Investigation, Don Fort, recently stated: “It’s possible to use Bitcoin and other cryptocurrencies in the same fashion as foreign bank accounts to facilitate tax evasion.” The IRS Criminal Investigation Unite (IRS-CI) has a number of investigators that are focusing on international crimes. […]
If IRS wants to obtain records held in another country, Don’t ignore its request!
If IRS wants to obtain records held in another country, Don’t ignore its request! – JD Supra. At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982 (IRC 982). […]
Beware of Sales or Transfers of 10% ownership in a Foreign Corporation
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)?
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 […]
