News & Analysis as of

Tax Liability

U.S. Internal Revenue Service Cancels Offshore Amnesty Program

by Butler Snow LLP on

The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more

New Tax Law May Result in Additional Taxes for Certain US Persons who Directly or Indirectly Own Equity in a Foreign Corporation

by White & Case LLP on

The new federal tax rules (informally known as the Tax Cuts and Jobs Act ("TCJA")), signed into law on December 22, 2017, significantly expand the situations in which a foreign corporation will be treated as a "controlled...more

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

by Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Key Federal Inflation-Adjusted Amounts for 2018

by Charles (Chuck) Rubin on

In Rev.Proc. 2018-18, the IRS has released various tax rates, brackets, and threshold amounts for 2018, incorporating inflation adjustments and the new tax act....more

Shareholders of S Corps can defer payment of Transition Tax

by Foodman CPAs & Advisors on

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

Decoding the Tax Cuts and Jobs Act – Part VII: Family Matters and Major Events in the Lives of Individuals

by Garvey Schubert Barer on

The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more

Foreign Account Reporting: Time Limit for IRS Action

by Moskowitz LLP on

To conduct an audit or otherwise take action on a tax return, the IRS must generally act within three years from the later of either the return’s due date or the date it was filed. That time limit may be extended to six years...more

Are Workers' Comp Benefits Ever Taxable?

In the vast majority of cases, workers’ compensation benefits are fully tax exempt, at the federal, state and local level. But this is not always the case where the workers' comp beneficiary is also receiving Social Security...more

Lawyers' Lawyer Newsletter - Recent Developments in Risk Management - March 2018

by Hinshaw & Culbertson LLP on

Lateral Hires – Screening – Moonlighting – Due Diligence by Hiring Firm – Vicarious Liability because of Lawyer's Apparent Authority - McFarland v. Niekamp, Weisensell, Mutersbaugh & Mastrantonio, LLP, 2017-Ohio-8394, 2017...more

No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers

by Foodman CPAs & Advisors on

The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...more

OIPA challenges GPT petition

by GableGotwals on

The OIPA is challenging a recently filed constitutional amendment that would eliminate the state's two-tiered gross production tax system, resulting in a 250 percent, potentially retroactive, tax increase on the states oil...more

Newman’s Own Law

A last minute addition to the budget appropriations bill enacted by Congress this month has created new opportunities for philanthropic planning. Section 41110 of the bill creates a limited exception from the private...more

Time to Reconsider Your Choice of Entity?

One of the most publicized changes made by last year’s Tax Cut and Jobs Act was a reduction in income tax rates for corporations and individuals. The maximum corporate tax rate has been permanently reduced from 35% to 21%,...more

The IRS is on to Crypto

by Foodman CPAs & Advisors on

The IRS Chief of Criminal Investigation, Don Fort, recently stated: “It’s possible to use Bitcoin and other cryptocurrencies in the same fashion as foreign bank accounts to facilitate tax evasion.” ...more

Virtual Currency Tax Consequences

by Carlton Fields on

A growing number of startups are offering virtual currencies to investors through initial coin offerings (ICOs) as a way to raise capital, often with little or no awareness of the tax consequences of their actions....more

The Use of Expert Testimony in Tax Court, Part II

by Moskowitz LLP on

In Part I, we introduced the Feinberg vs. Commissioner of Internal Revenue case, which demonstrates the financial challenges faced by marijuana businesses due to their inability to deduct ordinary and necessary business...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

A quiet Monday appears to be leading to a busy Tuesday morning, with Qualcomm upping its bid for NXP (in a move that could help it fend off Broadcom) and Albertson’s looking to join forces with what’s left of Rite Aid Corp...more

Court Orders Jacobson Remand to Determine Reasonableness of $10 Million Fine

In United States v. Zukerman, No. 17-948 (2d Cir. Feb. 6, 2018) (ALK, RAK, RSP) (summary order), the appellant, Morris Zukerman, challenged the substantive and procedural reasonableness of his sentence, which was imposed...more

Wire Transfer Audits and FATCA: What Every Taxpayer Needs to Know

FATCA: The Foreign Account Tax Compliance Act was signed into law by President Obama on March 18, 2010. There are two purposes for FATCA....more

If IRS wants to obtain records held in another country, Don’t ignore its request!

by Foodman CPAs & Advisors on

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982...more

The Tax Credit is Live: Pennsylvania Now Accepting Brewery Applications for Capital Excise Tax Credits

The time has finally come! After a long wait, the Pennsylvania Department of Revenue has released the application form for Pennsylvania breweries to apply for Capital Excise Tax Credits. Expired since 2008, the Malt...more

New Tax Bulletin Will Change the Tax Landscape for Many Foreign Universities in China

by Hogan Lovells on

As U.S. colleges and universities rapidly internationalize, it's unsurprising that institutions are increasingly entering the Asian market, especially in China where the student demand for international programs is especially...more

Michigan Property Tax and Civil Tax Collection Suits

by Dickinson Wright on

Civil suits to collect property taxes as an in personam debt are now limited to the person who owned the property when the tax became due, but the Michigan act does not completely prevent collection of property taxes as an in...more

The Use of Expert Testimony in Tax Court, Part I

by Moskowitz LLP on

The IRS is very aggressive in its audits of marijuana businesses, doing “random audits” of nearly everyone in the industry – particularly if their operations are large and profitable. A recent case involving the owners of a...more

Court Orders Jacobson Remand to Determine Reasonableness of $10 Million Fine

In United States v. Zukerman, No. 17-948 (2d Cir. Feb. 6, 2018) (ALK, RAK, RSP) (summary order), the appellant, Morris Zuckerman, challenged the substantive and procedural reasonableness of his sentence, which was imposed...more

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