All post, news and/or advice regarding compliance whether taxes, immigration or investments.
Signed into law in early July, the One, Big Beautiful Bill Act (OBBBA) introduces significant changes to tax law— impacting high-net-worth individuals (HNWIs). From new rules on global income tax (GILTI) to expanded opportunities for Qualified Small Business Stock (QSBS) investments, and much more, understanding and planning for these changes is essential.
Younger, affluent investors are increasingly turning to alternative investments, and may overlook the complex tax consequences that arise from these investments, including K-1 and pass-through income, which can lead to tax and estate planning headaches.
It’s been a busy year for global tax issues, between the Global Minimum Tax, worldwide calls for a wealth tax, and significant judicial decisions in the United States…
Amidst the upheaval of the COVID-19 pandemic, some U.S. taxpayers were unable to file their 2019 or 2020 income tax returns within the IRS’ filing deadlines The Internal Revenue Service, in a show of understanding, fully waived penalties for individual taxpayers and businesses who filed certain late returns by September 30, 2022.
Announced in June, the Joint Strategic Emerging Issues Team, or JSEIT, combines expertise from units across the agency, including Criminal Investigation, Tax Exempt/Government Entities, Large Business & International, and Small Business/ Self Employed.
In the first 12 years of the U.S. Foreign Account Tax Compliance Act, the IRS has spent nearly $600 million on enforcement but has only managed to collect $14 million in penalties in return. This poor performance indicates that the agency strongly needs to revise its enforcement strategy according to a recent audit report by the Treasury Inspector General for Tax Administration.
IRS Form 926 is the form U.S. citizens and entities including estates and trusts must file to report certain exchanges or transfers of property to a foreign corporation. This would include transfers of cash over $100,000 to a foreign corporation, or situations in which the transfer of cash resulted in owning more than 10% of the foreign corporation’s stock. This reporting requirement applies to outbound transfers of both tangible and intangible property
The Pandora Papers, a recent reveal of pervasive cross-border financial crime and elaborately-crafted tax dodging structures, as reported by a global network of investigative journalists, has
already shaken up governments and elections, upended tax authorities and initiated criminal investigations… Perhaps the most intriguing revelation of all from a stateside perspective was the emergence of South Dakota as a preferred tax haven of the rich and famous.
The U.S. Congress designed the Foreign Investment in Real Property Tax Act (FIRPTA) to collect tax on the sale of a U.S. property by a foreign person or business entity in order to ensure that foreign persons and entities paid tax on their U.S. source (situated) income (i.e., extract a type of capital gains tax that would normally not apply). Looking to boost tax revenues in a tough year of the Covid-19 pandemic, on On October 5th and Sept. 14. 2020, the IRS Large Business & International Division (LB&I) issued notices regarding their resumption of a FIRPTA enforcement campaign.
Breaking Tax News as of April 21, 2020: The following is an addendum to our original blog post of April 20, 2020 entitled:
“The Perfect Storm of Timing, Tragedy and Tax Law: NRAs and Covid-19”
Recognizing the unusual circumstances non-resident aliens have faced while sick, trapped or morally obligated to remain in the USA during the Covid-19 pandemic, the U.S. Department of Treasury has relaxed rules regarding what is commonly referred to as “the substantial presence test.”