Welcomed Tax Relief to U.S. Individuals Owning Stock in “Controlled Foreign Corporation”

The US Department of the Treasury last week clarified that US individual shareholders will be eligible for 50 percent relief from the new global intangible low-taxed income (GILTI) tax. GILTI was introduced by the Tax Cuts and Jobs Act 2017

Should I aggregate different businesses for wage and qualified property calculation purposes, or consider them to be separate on to maximize my 20% Section 199A deduction?

Internal Revenue Code Section 199A was enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), and slightly modified in 2018. This provision provides a tax deduction of up to 20% of the net income that a taxpayer receives

Should my business pay more wages or have qualified property to have a full 20% of profits Section 199A deduction, if you are a high earner taxpayer?

Internal Revenue Code Section 199A was enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), and slightly modified in 2018. This provision provides a tax deduction of up to 20% of the net income that a taxpayer receives

Is my trade or business a “Specified Service Trade or Business” and is my taxable income more than the amount that permits me to have a full 20% Section 199A deduction?

Internal Revenue Code Section 199A was enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), and slightly modified in 2018. This provision provides a tax deduction of up to 20% of the net income that a taxpayer receives

If you are a landlord, what changes need to be made to assure that you can be considered to be an active trade or business to qualify for the Section 199A deduction if you have net income from the rentals?

Internal Revenue Code Section 199A was enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), and slightly modified in 2018. This provision provides a tax deduction of up to 20% of the net income that a taxpayer receives

Significant FBAR Penalties Upheld by Court

Taxpayers have lost and the US Internal Revenue Service has scored a victory over the taxpayer in Kimble v USA, a court case concerning the reporting of foreign bank accounts. The taxpayer, Alice Kimble, held Swiss accounts at both HSBC and UBS in

Analysis: IRS New Disclosure Program

On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. The new voluntary disclosure procedure provides uniformity to offshore

IRS Updated Voluntary Disclosure Practice is a Game-Changer

Last week the IRS released a memorandum with new procedures for  an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer for offshore voluntary disclosures for US persons with unreported foreign assets. The

New Jersey Tax Amnesty program

Today the New Jersey Division of Taxation announced the launch of their Tax Amnesty program. The program is intended to provide individuals and businesses with the opportunity to pay back taxes or file past returns with no penalties and reduced

The IRS can revoke your passport

If you do not pay your taxes, the IRS may revoke your passport. As the National Taxpayer Advocate (NTA) Nina E. Olson has recently pointed out in her blog, when a taxpayer is notified of such pending revocation, that the taxpayer, nor

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”).

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

IRS Issue Number:    IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program

The 65-Day Rule: What Every Trustee Should Know about Taxes

Happy New Year!  With the close of the calendar year behind us, tax season is just beginning for individuals and many entities.  If you are serving as the trustee of a complex trust, however, it’s not too late to take

Some FBAR Deadlines Extended

Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain

IRS Announces New international campaigns

On November 3, 2017, the IRS announced an additional 11 compliance campaigns as areas of focus for the Large Business & International Division (“Announcement”). The 11 newly identified campaigns focus primarily on international issues, with seven international campaigns and four

IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do

An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax

Beware IRS Forms W-8

Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign non-US entities or persons (citizens and corporations) in order to

Powerful Post-death Planning Strategies for Trusts and Estates

After a client passes away, there is much more to do than just prepare a final Form 1040, U.S. Individual Income Tax Return. Taking control of the postmortem planning process can be a powerful way to save tax dollars for

IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party

The long awaited revised IRS Form W8-BEN has been recently released in July  2017.  The major changes to IRS Forms W8, particularly W-8BEN-E (which is still in draft form), have been driven by the changes in the law under FATCA. The new IRS

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