May I continue excluding income earned in a Foreign country after 2017?
May I continue excluding income earned in a Foreign country after 2017? – JD Supra 4/10/18. For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA. For others, provisions of the TCJA will affect […]
Common Reporting Standard (CRS) Reporting Avoidance Game Is Over
Common Reporting Standard (CRS) Reporting Avoidance Game Is Over – JD Supra 4/6/18. The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018. The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes in the Common Reporting Standard (CRS) that there are potential and […]
Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018
Taxpayers with undisclosed foreign accounts need to COME FORWARD NOW. Offshore Voluntary Disclosure Program Ends September, 2018 – JD Supra 4/3/18. On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). OVDP has been available to Taxpayers that willfully failed to report foreign financial assets and […]
20% Tax Deduction for Pass-Through Entities?
20% Tax Deduction for Pass-Through Entities? – JD Supra 3/27/18. IRS defines Pass-Through entities as: “an entity that passes its income, loss, deductions, or credits to its owners. The owners may be partners, shareholders, beneficiaries, or investors. It usually does not have an entity level income tax liability”. In the U.S., Pass-Through entities comprise 90% […]
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.
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 […]
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 […]
