The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more
In a prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s recently issued decision in Alon Farhy v. Commissioner, 160 T.C. No. 6 (April...more
The Continuing Saga of U.S. Tax Classification of Foreign Trusts and Related Penalty Issues -
In Greek mythology, Cerberus, a three-headed dog, was known as the guardian of the underworld. In more recent literature, a...more
One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more
On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more
9/1/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform
As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more