Consider a tax legal opinion to confirm clients’ 199A Specified Service Trades or Businesses (SSTB) status
On Aug. 8, 2018, the IRS released proposed regulations around the centerpiece provision of the Tax Cuts and Jobs Act. The new Section 199A tax deduction provides owners of sole proprietorships, partnerships, trusts and S corporations a significant 20 percent deduction
IR-2019-23, February 27, 2019 WASHINGTON ― The Internal Revenue Service today reiterated its warning that taxpayers may not be able to renew a current passport or obtain a new passport if they owe federal taxes. To avoid delays in travel plans, taxpayers
We have recently published the below article in Money Life, a weekly online finance magazine. https://www.moneylife.in/article/make-sure-you-have-filed-fatca-compliance-certifications/56190.html Many Indian banks and financial institutions have in recent years been requesting customers to complete a “FATCA Compliance Certificate”. The reason for the request
A Quiet Disclosure occurs when a person intentionally files tax returns (either amended or original returns, FBARs, and/or other International Informational Returns) outside of one of the IRS’ formal voluntary disclosure In other words, the individual submits the returns and
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
Enacted legislation requires the New Jersey Division of Taxation to establish a 90-day state tax amnesty period that ends no later than January 15, 2019. The Legislature had previously passed a bill requiring a six-month amnesty period that had to
Our article on the new tax law was published today by the American Bar Association below… https://www.americanbar.org/groups/gpsolo/publications/gpsolo_ereport/2018/june-2018/tcja-future-american-taxpayers.html The TCJA and the Future of American Taxpayers Vol. 7, No. 11 Parag Patel and Anannya Tripathy Parag Patel, Esq., is a tax attorney in
The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take notice and become compliant. The
In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR forms from 2006 through 2008.
The Internal Revenue Service advised tax professionals today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The new tax law signed last week in Washington prohibited the deduction of prepaid
President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week. The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,
The Government of India continues to crackdown on self-certifications and know your customer (KYC) compliance for financial accountholders. Earlier this month the government said that the account holders of any financial institutions need to provide self-certification of compliance under US
The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship, to check if they have a U.S. tax liability and a filing requirement. At the same time, the agency advised anyone with a foreign
One of the tax planning tools available to executors of estates is the 663(b) election, also known as the “65-day rule.” Simply put, a 663(b) election allows distributions made to beneficiaries within 65 days of year-end to be counted as
U.S. taxpayers with unreported foreign accounts or assets are in a challenging position. The IRS has repeatedly announced that it is devoting resources to finding and penalizing taxpayers who do not disclose such offshore accounts and assets. In addition, many U.S. taxpayers,
US-India Cooperation: In 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. Under the agreement, Indian financial
There are many missed opportunities to solve tax problems with the IRS through the IRS Appeals office. Below is a list of the most common IRS letters and notices affording an IRS appeals opportunity. Letter 11 – Final Notice of
The IRS has redesigned its correspondence notices to be more “user friendly.” This is supposed to make their notices easier to understand and therefore allow responses to occur in a more effective and efficient manner. IRS tax notices will now
What is a foreign grantor trust (“FGT”). A FGT is typically used when a non-U.S. Person individual (i.e., an individual who is a non-U.S. citizen, not a “green card” holder, or otherwise not considered a U.S. income tax resident) wishes
The IRS has tightened its enforcement of the Foreign Account Tax Compliance Act (“FATCA”). FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs), i.e., foreign banks, to
Every startup grants stock options sooner or later. Below is checklist for private corporations (not LLCs) granting stock options. Prior to Granting Stock Options Adopt a stock option plan – First, adopt a plan and draft standard stock option agreements
Which is better: an Incentive Stock Option (aka a statutory stock option) (an “ISO”) or a Nonqualified Stock Option (aka a Nonstatutory Stock Option) (an “NQO”)?
Many of our clients often ask: Which is better: an Incentive Stock Option (aka a statutory stock option) (an “ISO”) or a Nonqualified Stock Option (aka a Nonstatutory Stock Option) (an “NQO”)? What are the differences between ISOs and NQOs?