Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
To bring Hong Kong’s Foreign-Sourced Income Exemption (FSIE) regime in line with the European Union’s updated guidance on FSIE regimes promulgated in December 2022, the Inland Revenue (Amendment) (Taxation on Foreign-sourced...more
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
Is it possible for the IRS to leave more in our paychecks in 2024? What has changed for the 2024 federal income tax brackets and how will these apply to the tax return(s) you’ll file in 2025?...more
The IRS recently announced the 2024 annual inflation adjustments for key tax provisions. Of interest to our clients, • Standard Deduction: The standard deduction for married couples filing jointly increases by $1,500 to...more
It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
Short Summary: The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more
On October 18, 2022, the Internal Revenue Service (IRS) announced the annual inflation adjustments for 2023 related to more than 60 tax provisions, with some increasing, some maintaining and some new additions to the list...more
Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more
On August 10, 2022, a petition for writ of certiorari filed by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool)...more
U.S. citizens and resident aliens who live abroad are taxed on their worldwide income. But such taxpayers may qualify for the foreign earned income exclusion, which allows certain taxpayers to exclude up to $112,000 (in...more
California Assembly Bill 71 would have made major changes to how California taxes foreign income, including a thinly-veiled attempt to get multinationals to elect worldwide combination. It looks like the bill will not pass...more
Consider the estate tax planning implications before relocating - Suppose you’re contemplating a bold move — literally: pulling up stakes and moving to a foreign country. There are many possible reasons for this drastic...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 22, 2021 – February 26, 2021... February 25, 2021: The IRS issued an alert warning...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020... August 24 2020: The IRS published a memorandum concerning...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020. February 24, 2020: The IRS released final instructions to Form 8978,...more
IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017. ...more
Most states have historically not subjected foreign-source income to state income tax. Consequently, since the passage of TCJA, the vast majority of states have opted not to tax GILTI (with most states explicitly decoupling...more
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more
On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more