News and postings related to taxes in the U.S.
How has a relatively minor tax bill — $14,729 to be exact — turned into one of the most important tax cases for the United States? The matter at hand is whether the United States federal government can tax unrealized gains as income in Moore v. United States (Docket 22–800)…
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.
2022 has been an unpredictable year amidst soaring inflation and geopolitical unrest. In the tax realm, governments have been trying to hedge against this uncertainty by shoring up their budgets and addressing inconsistent tax enforcement.
While U.S. citizens and persons who are deemed to be domiciled can enjoy an estate tax exemption in 2022 of $12,060,000, that figure does not apply to nonresident aliens. The exemption amount for a nonresident alien decedent is actually only $60,000, and any amount that exceeds that figure is subject to estate tax that ranges anywhere from 26% – 40% . The estate tax exemption applies to all assets, not just real estate. Real estate property falls under the blanket estate tax exemption if the property is an asset in a decedent’s estate.
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
This blog post is an update to IWTA founder Jack Brister’s article published in JD Supra on March 18, 2022, entitled, “Frozen: How the Revocation of the U.S. – Russia Tax Treaty Puts Global Trade on Thin Ice.” The Biden administration is poised to fully block Russia’s ability to pay U.S. bondholders. The Treasury Department told multiple news outlets that it had suspended its tax information exchanges with Russia. Read more…
For taxing authorities around the world, monitoring taxpayer disclosures and transparency will be a top line item in 2022, meaning taxpayers — especially high-net-worth individuals and corporate entities — should expect more scrutiny into their affairs. Governments are in a unique position as they navigate multiple demands and pressures.
The long-awaited infrastructure proposal was approved by Congress late last week and has been signed into law by President Joe Biden. As part of the President’s mission to “build back better,” the proposal is a considerable investment in the country’s infrastructure.
And while not as large as once envisioned — originally, it was $3.5 trillion — it is still a substantial amount at $1.2 trillion. Funding for the Infrastructure Bill will come from a few sources.
International tax expert Jack Brister comments on some of the tax changes that will impact businesses and investors.
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.