News & Analysis as of

Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

by Mintz Levin on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

MTC Marketplace Seller Voluntary Disclosure Initiative Underway

by McDermott Will & Emery on

On August 17, 2017, the application period opened for the limited-time MTC Marketplace Seller Voluntary Disclosure Initiative opened and it will close October 17, 2017. Since our last blog post on the topic detailing the...more

Massachusetts Joins MTC Amnesty Program

Massachusetts Joins Multistate Tax Commission Amnesty Program - For Most States Amnesty Features Complete Tax Forgiveness - Urgent Action May Be Needed - Boston – On August 18, 2017 Massachusetts joined 22 other...more

The Importance of Timely Electing Your Foreign Earned Income Exclusion

Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas....more

AFRICA - A Legal Guide for Business Investment and Expansion: Tunisia

1. What role does the government of Tunisia play in approving and regulating foreign direct investment? The Tunisian government places a priority on attracting foreign direct investment. The Tunisian government...more

Tax Payment Plans: What Do You Do? (Part 3)

by McNair Law Firm, P.A. on

If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more

AFRICA - A Legal Guide for Business Investment and Expansion: Tanzania

1 .What role does the government of the United Republic of Tanzania play in approving and regulating foreign direct investment? The government plays an active role in approving and regulating foreign direct investment....more

When A Partner May Not Be Acting As A Partner

by Farrell Fritz, P.C. on

It is not uncommon for a partner to engage in a business transaction with a partnership of which he is a member. If the partner engages in a transaction with his partnership other than in his capacity as a partner, he will be...more

Failure to Disclose Adjusted Basis on Disclosure Form Costs Taxpayer $33M+ Charitable Deduction

by Charles (Chuck) Rubin on

Under Treas. Regs. §1.170A-13, taxpayers making substantial noncash charitable contributions are required to disclose information regarding the contribution on Form 8283. ...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

AFRICA - A Legal Guide for Business Investment and Expansion: South Africa

1 .What role does the government of South Africa play in approving and regulating foreign direct investment? South Africa is a constitutional democracy and an active member of the international investment community. It...more

Are Trusts Still Useful If the Estate Tax Is Repealed?

With Republicans in control of Congress and the presidency, there is talk of eliminating the federal estate tax. In 2017 the tax affects only estates over $5.49 million, meaning that for more than 99 percent of Americans,...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its Interest In A U.S. Partnership Is Not U.S.-Source Income Unless...

by Roetzel & Andress on

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue (filed on July 13, 2017), the United States Tax Court overturned Revenue Ruling 91-32 (which had been relied on since 1991) and...more

AFRICA - A Legal Guide for Business Investment and Expansion: Nigeria

1 .What role does the government of nigeria play in approving and regulating foreign direct investment? Due to the economic benefits that accompany Foreign Direct Investment (FDI), the Nigerian government strives to...more

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

China implements new tax and administrative measures to boost foreign investment

by DLA Piper on

The Standing Committee of the China State Council, in their meeting of 28 July, released a strong signal on the encouragement of foreign investment in China. The meeting resulted in several particular measures aiming to...more

Rehabilitation for residential use in Lisbon’17: supply and legal regimes for foreigners

by DLA Piper on

Portugal currently offers two attractive legal/tax regimes for foreigners who wish to buy a property in the country and live here. Get to know them. Tax regime for non-habitual residents - What is the Non-Habitual...more

Securitisation in Poland: Legal and tax aspects

by Hogan Lovells on

Securitisation transactions have been receiving increased attention as attractive alternatives for Polish companies, especially those who can derive large pools of receivables from the debtors which are consumers or...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Controlled Foreign Corporation: Neither A Lender, Guarantor, Nor Pledgor Be?

by Farrell Fritz, P.C. on

Last week, we considered the U.S. taxation of a closely held foreign corporation that owned a minority interest in a partnership that was engaged in business in the U.S. This week, we turn our sights to the U.S. taxation of a...more

You Owe IRS Taxes: What Do You Do? (Part 1)

by McNair Law Firm, P.A. on

Many individuals and businesses owe taxes to the IRS, or they have not filed their tax returns or both. While the IRS may be the most powerful creditor in the world, there are solutions. This is Part I of a series addressing...more

Implications of Federal Partnership Audit Rules for State and Local Taxation

by McDermott Will & Emery on

The new federal partnership income tax audit rules, scheduled to take effect on January 1, 2018, will have significant implications for the state and local taxation of partnerships and their partners. Most, but not all,...more

California State Board of Equalization Gutted

The Taxpayer Transparency and Fairness Act of 2017 - Established by the California Constitution in 1879, the California State Board of Equalization (the “BOE”) has been the agency charged with administering most of the...more

AFRICA - A Legal Guide for Business Investment and Expansion: Ghana

1. What role does the government of Ghana play in approving and regulating foreign direct investment? The Government of Ghana continues to promote foreign direct investment in Ghana. In 2013, the Ghana Investment Promotion...more

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