Category: Us Tax

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..

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..

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..

In November 2017, the United States Congress’ House of Representatives House Ways and Means Committee released its version of a tax reform Bill entitled the Tax Cuts and Jobs Act of 2017 (H.R. 1) (the “Bill”).  The Bill seeks to reform the Internal Revenue Code, reducing the top corporate tax … Read More..

Foreign investors can minimize the tax hit on property purchases but good advice and a lot of paperwork is needed.

If you live in Tel Aviv and want to buy a home in Miami for your daughter while she goes to University, you have a lot more to think about than … Read More..

Establishing a foreign corporation to buy and own U.S. real estate remains a legitimate basic planning tool that international buyers might wish to consider.
Taking title in offshore companies provides several benefits. First, it allows a foreign buyer to avoid the federal estate tax and the necessity of a domestic probate … Read More..