The Tax Cut and Jobs Act (TCJA) has brought significant changes to the U.S. taxation of foreign income. For decades, the income of certain foreign subsidiaries was only taxed in the U.S. upon repatriation of the income to the U.S. entity. The TCJA changed this deferral regime to a system
As you’re settling in for the holidays, and taking shelter from the winter weather with a warm fire and mug of cocoa, don’t forget to take one last look at your tax planning opportunities before the end of the year. The Tax Cuts and Jobs Act (TCJA) made major changes
In a recent, well-reasoned case, the Sixth Circuit upheld a taxpayer’s use of an IC-DISC as a Roth IRA investment to accumulate earnings tax-free. The investment was established by the following steps: Roth IRA owns shares of Holding Company (Holdco); Holdco owns shares in IC-DISC, a tax-exempt entity for export
Last year, more than 875,000 taxpayers were victims of tax identity theft. Identity thieves have capitalized on the filing of phony tax returns to gain access to millions of dollars of fraudulent tax refunds by using the names, social security numbers, or W-2 information of unsuspecting taxpayers. Tax identity theft
The U.S. Department of Commerce Bureau of Economic Analysis (BEA) requires all U.S. persons (individuals and businesses) that owned an interest in a foreign affiliate during their fiscal year 2014 to file a Form BE-10 to report the ownership. The filing requirements have been interpreted broadly to include a U.S.
The IRS recently made additional changes to the Streamlined Domestic Offshore Procedures to make it easier for U.S. individual taxpayers to come into compliance with international income reporting. Like other iterations of the program, these changes are designed for individuals whose failure to comply with the regulations was non-willful. The