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Tax Liability Income Taxes

Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits

by Ropes & Gray LLP on

In this Ropes & Gray podcast, tax counsel Morey Ward is joined by tax partner Kendi Ozmon and tax counsel Gil Ghatan to discuss one of the key provisions for tax-exempt organizations from the Tax Cuts and Jobs Act (TCJA) –...more

Draft North Carolina Tax Legislation Released

by Smith Anderson on

On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

The 2018 IRS Dirty Dozen,Part III: Abusive Tax Shelters, Offshore Tax Schemes, and Frivolous Tax Arguments

by Moskowitz LLP on

In this post we continue our coverage of tax evasion schemes with three that make it to the IRS Dirty Dozen list every year: Abusive tax shelters, offshore tax schemes, and frivolous tax arguments....more

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

by Foodman CPAs & Advisors on

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

IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax

by Fenwick & West LLP on

This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more

Bracewell Tax Report: March 2018

by Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Alabama Legislature Passes Bill to Address Calculation of Credit for Taxes Paid to Other States - State & Local Tax Alert: Alabama...

Gov. Kay Ivey signed House Bill 384, into law last Wednesday, March 28, ending a debate that has lasted for almost a decade over the scope of the individual income tax credit for certain taxes paid to other states. ...more

Taxation of Virtual Currency Transactions

by Snell & Wilmer on

With the use of virtual currency on the rise, questions emerge as to how virtual currency transactions are taxed. The IRS has issued guidance regarding the tax consequences of such transactions, answering some questions but...more

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

by McDermott Will & Emery on

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

The Tax Laws Changed. Should Your Business and Estate Plans Change Too?

by Thompson Coburn LLP on

On January 1, 2018, the most significant changes to the U.S. tax code in 30 years took effect. While the permanency of these changes varies, they are all currently scheduled to continue until at least 2026, which is long...more

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

by McNair Law Firm, P.A. on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

by Pepper Hamilton LLP on

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

IRS and Accuracy

by Foodman CPAs & Advisors on

According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...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

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

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

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

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

Uncle Sam Says Give Me Your Money or Your Passport

by Miles & Stockbridge P.C. on

A “seriously delinquent tax debt” will affect the ability of a U.S. citizen to use, or apply for, a passport. Section 7345 of the Internal Revenue Code (“IRC”) permits the Secretary of State to deny, revoke or limit a...more

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

by Foodman CPAs & Advisors on

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

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

by Foodman CPAs & Advisors on

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

Examining the cultural shift on tax avoidance

Against the backdrop of the Panama and Paradise Papers, legal tax avoidance has become a significant moral challenge for companies. Our latest Financial Crime Conversation looked at the cultural shift on tax....more

Two years in Switzerland helped Tulsa attorney professionally

by GableGotwals on

The Internal Revenue Service can come knocking on doors of U.S. citizens living in many foreign countries to collect taxes. Caught off guard with this unexpected obligation, many who don’t know they are U.S. citizens seek...more

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Why are US Citizens Renouncing their Citizenship?

by Foodman CPAs & Advisors on

A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more

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