This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
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 25 – January 29, 2021 - Costello v. Comm’r, T.C....more
As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more
Self-employment creates additional challenges from an income tax perspective. Self-employed individuals must keep careful track of their business expenses so they can properly compute their income. For a professional...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe...more
Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated. Each of these has its own corresponding penalties and generally applies to United States...more
Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more
Yes. Most countries tax their citizens based on where those citizens reside. However, U.S. citizens are required to report their worldwide income. Therefore, if you are a U.S. citizen who owns income producing property in...more
On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the...more
Rental income is reportable on a Taxpayer’s tax return. Certain expenses such as mortgage interest, real estate taxes, casualty losses, maintenance, utilities, insurance, and depreciation may be deducted from a Taxpayer’s...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
In Taxpayer Alert TA 2017/1, the Australian Tax Office (ATO) has announced that it will be targeting arrangements which fragment integrated trading businesses, with particular emphasis on the inappropriate use of stapled...more
One of the most vexing tax issues remaining unresolved since the 1986 enactment of the passive loss (PAL) rules is whether business or rental income earned by a trust can be active income and whether business or rental losses...more