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
2/7/2020
/ Double Taxation ,
Foreign Corporations ,
Foreign Earned Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Transition Tax
IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes. The owners of an S-Corp report the...more
Form 5472 is an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose of Form 5472 is to provide information when “reportable transactions” occur...more
7/1/2019
/ Beneficial Owner ,
Disregarded Entities ,
Financial Transactions ,
Foreign Corporations ,
Foreign Persons ,
Foreign-Owned Corporations ,
IRS ,
Reportable Events ,
Required Forms ,
Tax Cuts and Jobs Act ,
Tax Penalties ,
Tax Planning ,
Tax Reform
Taxpayers can either itemize or take the standard deduction. They can’t do both. Many Taxpayers that were able to itemize deductions in prior tax years are unable to do so in Tax Year 2018 because the Tax Reform has made it...more
Many Taxpayers might be faced with an unexpected tax bill during the 2018 Tax season. Many Taxpayers did not alter their tax withholding in their paychecks to reflect the changes in the Tax Reform. ...more
4/11/2019
/ Debt Collection ,
Income Taxes ,
Installment Agreements ,
IRS ,
Offer-in-Compromise ,
Tax Cuts and Jobs Act ,
Tax Debt ,
Tax Extensions ,
Tax Planning ,
Tax Reform ,
Tax Refunds ,
Trump Administration
The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more
As 2018 comes to an end, many Taxpayers are wondering about their tax reporting situation under the Tax Cut Jobs Act. Taxpayers ought to be asking themselves if their Tax Representative understands...more
1/4/2019
/ Corporate Taxes ,
CPAs ,
HELOC ,
Income Taxes ,
IRS ,
SALT ,
Tax Advice ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns
The Tax Cut and Jobs Act (TCJA) amended Section 274 of the Internal Revenue Code (IRC) created a confusion for Taxpayers by disallowing a deduction for expenses with respect to “entertainment”, amusement, or recreation and...more
11/29/2018
/ Accounting Controls ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Meal and Entertainment Expenditures ,
Reimbursements ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
There are investors that have an interest in “exchanging or swapping” Virtual Currency (VC). Prior to the passage of the Tax Cut and Jobs Act (TCJA), VC investors could take the position that if they “exchanged or swapped”...more
7/2/2018
/ Bitcoin ,
Cryptocurrency ,
Digital Currency ,
Ethereum ,
Financial Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Swaps ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Virtual Currency
On May 23, 2018, IRS released Notice 2018-54 to inform Taxpayers that IRS, in the near future, will be releasing proposed regulations, to assist Taxpayers with understanding the relationship between federal charitable...more
Here are the changes from the Tax Cut and Jobs Act (TCJA) that will impact “most” Individuals when they prepare their 2018 Tax Returns in 2019...more
5/18/2018
/ Affordable Care Act ,
Alimony ,
Charitable Donations ,
Child Tax Credit ,
Corporate Taxes ,
Income Taxes ,
Mortgage Interest ,
New Legislation ,
Pass-Through Entities ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more
For most Expatriates, very little changes under the Tax Cut and Jobs Act (TCJA) because “foreign earned income” continues to be treated the same way for Individual Taxpayers under the TCJA. For others, provisions of the...more
IRS defines Pass-Through entities as: “an entity that passes its income, loss, deductions, or credits to its owners. The owners may be partners, shareholders, beneficiaries, or investors. It usually does not have an entity...more
The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code. One of them is the tax on Global Intangible Low-Taxed Income (GILTI). Beginning with...more
The Sunshine State is one of the lowest tax burden states in the US. Florida has no state individual income tax. At the state level, there is NO tax on social security benefits, retirement income, IRAs, 401(k) accounts,...more
3/19/2018
/ C-Corporation ,
Corporate Taxes ,
Florida ,
Franchise Taxes ,
Homestead Exemption ,
Income Taxes ,
Limited Partnerships ,
Property Tax ,
S-Corporation ,
Sales Tax ,
State and Local Government ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform
Since the early 1940’s, alimony payments have been tax deductible for the Payer Spouse. The recipient of the alimony (Recipient Spouse) paid the income tax on the alimony payments. The Tax Cuts and Jobs Act (TCJA) puts an...more
The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”...more
3/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
International Tax Issues ,
New Legislation ,
S-Corporation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Liability ,
Tax Planning ,
Tax Reform
La "Ley de reducción de impuestos y empleos" (la "Ley") contiene una provisión que es una "acompañante hermana" de la Deducción por Dividendos Recibidos (DRD) que implica ventas o transferencias que envuelven un 10% de la ...more
The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign...more
La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...more
2/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
New Legislation ,
Passive Foreign Investment Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...more
2/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
New Legislation ,
Passive Foreign Investment Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration