IRS lacks statutory authority to assess penalties under section 6038(b) for...
On April 3, 2023, the United States Tax Court ruled in Alon Farhy v. Commissioner, 160 T.C. No. 6 that the Internal Revenue Service (IRS) did not have authority to assess penalties under Internal...
View ArticleThe Downward Spiral of Downward Attribution
The Tax Cuts and Jobs Act (TCJA) created significant changes for both taxpayers and practitioners. One of the most disruptive and wide-ranging changes to taxpayers of TCJA was the repeal of Internal...
View ArticleNow that you own a controlled foreign corporation (CFC), are you GILTI?
An overview of Global Intangible Low-Taxed Income (GILTI) Prior to the enactment of the 2017 Tax Cuts and Jobs Act (“TCJA”), the United States generally taxed US taxpayers on their worldwide income....
View ArticleWhat does it mean to be a beneficiary of a trust?
A trust is a legal arrangement where the creator of the trust (called either a grantor or settlor) transfers legal title to property to a trustee to manage for the benefit of individual(s) or entities...
View ArticleWhy missing the June 15 tax deadline for US taxpayers abroad could be costly
If you are a US taxpayer (citizen, Green Card holder or resident) living abroad, this time of year can be taxing in every sense. Tax Filing Due Date Individual Income Tax Returns are normally due on...
View ArticleThe Corporate Transparency Implementation Overview
The Corporate Transparency Act will require certain US entities (and certain foreign entities) to report information relating to their ultimate Beneficial Owner to FinCEN. FinCEN issued its Final Rule...
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US Estate Tax Concerns for Non-US Persons Update
USTAXFS Tax Director, Patrick Hoza, provides the latest on US Estate Tax concerns for non-US persons. The United States imposes its Estate Tax not only on its citizens and residents but also on...
View ArticleMake Your Retirement Savings Last as Long as You Do
With rising life expectancies, it is possible that individuals will outlive their traditional retirement savings. A qualified longevity annuity contract (QLAC) provides a potential solution. What is a...
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UK Chancellor’s Autumn Statement Highlights
According to the Institute for Fiscal Studies, UK tax levels are at their highest since records began 70 years ago. After the usual speculation in the press over the last week, we learned today from...
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Top tips for 2023 US year-end tax planning
In Switzerland, Samichlaus, aka St. Nick, came to children this past night and brought them clementines and nuts. While we cannot transfer food through the internet, we have something almost as good –...
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