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

Traveling? Resolve Tax Debt Before Getting Your Passport

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

Make Sure You have Filed FATCA Compliance Certifications

We have recently published the below article in Money Life, a weekly online finance magazine. Many Indian banks and financial institutions have in recent years been requesting customers to complete a “FATCA Compliance Certificate”.  The reason for the request

IRS Has New Procedures for Scrutinizing Quiet Disclosures

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

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 Enacts Tax Amnesty Bill

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

The TCJA and the Future of American Taxpayers

Our article on the new tax law was published today by the American Bar Association below… 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

IRS reminds those with foreign assets about U.S. tax obligations

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

FBAR statute of limitations court case ruling

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.

IRS Advisory: Prepaid Real Property Taxes May Be Deductible in 2017 if Assessed and Paid in 2017

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

New 2018 Tax Law’s Business Tax Changes

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,

New 2018 Tax Law’s Individual Tax Changes: New Tax Brackets, Credits and Deductions

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,

4 tax strategies before Jan. 1 to lower your tax bill under the new tax law

  Give more to charity in 2017. Have you been meaning to donate? If so, get it done by year’s end. It helps reduce your income this year when tax rates are higher. Plus, you might not end up itemizing

India issues FATCA Self-certifications and KYC Warnings

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

IRS Issues Reminders for FBARs and other International Requirements

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

Using the 65-day rule as an opportunity for income tax savings for estate

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

Avoiding and Defining Willfulness

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,

Common Issues for US-India Tax Reporting

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

IRS Letters and Notices Offering an Appeal Opportunity

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

IRS Most Common Tax Notices and What They Mean

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

US Taxation of Foreign trusts: Foreign grantor trust

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

New Jersey to repeal estate tax

Last week, the New Jersey legislature announced its plan to repeal estate tax by January 2018.  The New Jersey estate tax is presently one of the highest in the nation. For state residents the estate tax exemption would be increased

Checklist for for granting stock options

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?


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