A taxpayer with shares in a passive foreign investment company (a “PFIC”) may qualify to make either a qualified electing fund (“QEF”) election or an election to apply mark-to-market treatment with respect to marketable...more
For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more
The Source of Income from the Sale of Personal Property Generally, income from the sale of personal property is “sourced” to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed...more
The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more
In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more
A passive foreign investment company (PFIC) is a foreign corporation that meets either of two tests: an Asset test or an Income test. A U.S. person who is a direct or indirect shareholder of a corporation that satisfies...more
Private Equity: Offshore Investments and Phantom Income - Private equity funds pool capital for investment in privately-held businesses. Increasingly, PE funds are looking to global investment markets and foreign...more
Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Sloane v. Commissioner TBL Licensing LLC v. Comm’r, Corrected 158 T.C. 1 | February 8, 2022 | Filed January 31, 2022 | Halpern, J. | Dkt. No....more
The Foreign Agents Registration Act (FARA), 22 U.S.C. § 611 et seq., is a federal statute passed in 1938 that was originally intended to combat the dissemination of Nazi and Communist propaganda within the United States. FARA...more
1/6/2022
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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of January 18 – January 22, 2021 -
Adams Challenge (UK)...more
1/27/2021
/ Business Expenses ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
Investment Management ,
IRS ,
Management Fees ,
Shareholder Distributions ,
Tax Deductions ,
Tax Planning ,
Tax Returns ,
Tax Treaty
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
10/8/2020
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Filing Requirements ,
Foreign Corporations ,
Foreign Tax Credits ,
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Statute of Limitations ,
Tax Returns