There are no adverse consequences, other than transaction costs, to engaging in tax planning before immigrating to the United States. However, there may be significant adverse tax consequences if you fail to engage in any tax...more
There are no adverse consequences, other than transaction costs, to engaging in tax planning before immigrating to the United States. However, there may be significant adverse tax consequences if you fail to engage in any tax...more
The recent pandemic has caused changes to our lives in multiple ways, including shelter-in-place orders and travel restrictions between various countries. ...more
States are updating their sales and use tax laws to collect taxes against a new world of frequent remote transactions. With the popularity of internet commerce and efficient interstate mails and wires, commerce increasingly...more
7/10/2019
/ Cryptoassets ,
Cryptocurrency ,
E-Commerce ,
Initial Coin Offering (ICOs) ,
Internet Retailers ,
Online Marketplace ,
Online Platforms ,
Out-of-State Companies ,
Retail Market ,
Sales & Use Tax ,
Substantial Nexus ,
Tax Liability ,
Tax Planning ,
Token Sales
After the reversal of long-standing precedent, more than 35 states have introduced bills or passed laws over the last year that would permit the collection of sales and use tax on remote transactions previously excluded from...more
7/10/2019
/ Cryptocurrency ,
Ethereum ,
Internet Retailers ,
Legislative Agendas ,
Online Gaming ,
Online Marketplace ,
Out-of-State Companies ,
Retail Market ,
Sales & Use Tax ,
State and Local Government ,
Substantial Nexus ,
Tax Liability ,
Tax Planning
Recently, I discussed the impact of so-called “soft letters” sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues....more
Trends Against BITS and Investor State Dispute Resolution -
In my first Expect Focus International article (http://bit.ly/2G9Demu), I suggested that investors doing business outside the United States should do so in...more
4/11/2018
/ Bilateral Investment Treaties ,
Business Disputes ,
Consumer Financial Products ,
Controlled Foreign Corporations ,
Foreign Investment ,
Foreign Workers ,
H-1B ,
Hiring & Firing ,
Immigration Procedures ,
Insurance Industry ,
International Arbitration ,
Life Insurance ,
Safe Harbors ,
Tax Cuts and Jobs Act
The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more
4/10/2018
/ Consumer Financial Products ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Life Insurance ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more
Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth....more