Articles

Despite all that’s been written about U.S. worldwide income taxation and complex informational reporting requirements, many individuals, particularly those living outside the U.S., remain noncompliant. Some individuals do not realize they are U.S.

citizens or tax residents. Some know they are U.S. citizens or residents but do not understand that … Read More..

Prior to the 2017 Tax Cuts and Jobs Act (Act), individual taxpayers were able to reduce their taxable income by deducting various investment-related expenses as miscellaneous itemized deductions. The Act suspended miscellaneous itemized deductions beginning in 2018 through January 1, 2026. As a result, investment advisory fees and other expenses … Read More..

Transfer pricing has gained more attention in recent years as more and more organizations conduct business internationally. With this increased activity, the IRS and other authorities around the globe have identified transfer pricing as an underused source of tax revenue.

In reality, effectively navigating transfer-pricing regulations may be less about … Read More..

The recent end of the OVDP is not the end of IRS enforcement of undisclosed offshore accounts.

For most of the past decade, the IRS has maintained a safe harbor for taxpayers who want to disclose offshore account holdings that may otherwise expose them to criminal penalties, and over the years, … Read More..

Recent changes to deductions and tax rates should guide

planning for the rest of 2018.

The Tax Cuts and Jobs Act (TCJA) made a large number of changes that affect individuals, including new tax rates, new rules for the child tax credit (“kiddie tax”), new thresholds for various capital gain rates, an … Read More..

U.S. shareholders of foreign corporations must include these foreign earnings and profit (E&P) amounts in income

The IRS issued proposed regulations on Wednesday on the Transition Tax (Sec. 965), which was added to the Internal Revenue Code by the law known as the Tax Cuts and Jobs Act (REG-104226-18). Sec. 965 … Read More..

Israeli companies need to examine the potential consequences of the US Sales Tax case (Wayfair) as states consider hunting for more tax dollars abroad

The Wayfair case, which was decided on June 21 and concerns state sales tax, sent shockwaves through the US tax system. It means US states will be able to collect … Read More..

Choosing the best business form is one of the most important preliminary decisions for a new investment or business owner doing business in the US.  There are several choices: C Corporation (C-Corp), S Corporation (S-Corp), Limited Liability Company (LLC), Limited Liability Partnership (LLP) or a Partnership.  There are advantages and … Read More..

More than a quarter of a million Americans are at risk of losing their passports unless they pay their taxes, according to a new study released by the US Treasury. And that’s because in February, the federal government started to enforce a law that was passed three years ago.

This year, the … Read More..

The US tax reform (or “Tax Cuts and Jobs Act”) was enacted on 22 December 2017 with most of the international provisions in force since the beginning of 2018.  The US tax reform includes both tax-reducing and tax-increasing measures, which generate new planning opportunities.

This brief will describe the obligations for … Read More..

For tax years beginning in 2018 and beyond, the Tax Cuts and Jobs Act (TCJA) created a flat 21% federal income tax rate for C corporations. Under prior law, C corporations were taxed at rates as high as 35%. The TCJA also reduced individual income tax rates, which apply to … Read More..

Implications for Corporations and Pass-Throughs
In the last several months, much has been written about the implications of the Tax Cuts and Jobs Act (TCJA).1 For owners of flow through entities (including sole proprietorships, partnerships, and S corporations), most of the commentary has focused on the new 20% deduction available for qualified business … Read More..

 
Individuals are being treated the same as big corporations
Expatriate Americans face unexpected tax bills on their overseas business interests under repatriation rules Congress designed to persuade companies like Apple and Google to bring back to the US profits they had accumulated in lower-taxed countries.

We believe large numbers of our clients … Read More..

The tax bill that President Trump signed into law in late December represents the most substantive changes to the federal tax code in 30 years, but Congress passed up its chance to clarify matters for cryptocurrency investors, traders, issuers and miners. The community is left with a host of questions and … Read More..

IRS Urges Travelers Requiring Passports to Pay Their Back Taxes or Enter into Payment Agreements; People Owing $51,000 or More Covered

The Internal Revenue Service has announced and encouraged the taxpayers who are seriously behind on their taxes to pay what they owe or enter into a payment agreement with the … Read More..