The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and...more
The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more
4/16/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Infrastructure ,
Inversion ,
Legislative Agendas ,
OECD ,
Tax Rates ,
Tax Reform
During the run-up to the November presidential election, then-candidate Joe Biden previewed his tax priorities to enact a more progressive tax code to roll back "giveaways" to wealthy individuals and corporations under the...more
4/9/2021
/ Biden Administration ,
Budget Reconciliation ,
Corporate Taxes ,
Federal Budget ,
Legislative Agendas ,
OECD ,
Parliamentary Procedure ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020. This compares to the previous annual record…...more
The U.S. Treasury Inspector General for Tax Administration (TIGTA) recently audited the Internal Revenue Service's (IRS) programs to ensure compliance by expatriates with the provisions under Sections 877 and 877A of the...more
In 2017, the IRS Large Business & International Division (LB&I) announced a new audit strategy known as "campaigns" that focused on issue-based rather than entity-based examinations, and focusing on those issues that present...more
The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
12/4/2019
/ AICPA ,
Criminal Investigations ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Financial Transactions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Tax Planning ,
Tax Returns ,
Virtual Currency ,
Voluntary Disclosure
In the "Relief Procedures for Certain Former Citizens" and accompanying FAQs, the Internal Revenue Service (IRS) provides a simplified pathway for certain non-compliant U.S. citizens who expatriated after March 18, 2010, to...more
Highlights -
• In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
7/15/2019
/ Controlled Foreign Corporations ,
Domestic Partnership ,
GILTI tax ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Minority Shareholders ,
New Guidance ,
New Regulations ,
Pass-Through Entities ,
Passive Foreign Investment Company ,
S-Corporation ,
Stocks ,
Subpart F ,
U.S. Treasury
• The Internal Revenue Service has issued a proposed regulation that in many cases should eliminate the detrimental U.S. tax consequences to a U.S. corporation under Section 956 of the Internal Revenue Code when the...more
11/9/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
Tax Cuts and Jobs Act