Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure -
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
1/25/2023
/ Business Entities ,
Corporate Structures ,
Corporate Taxes ,
FBAR ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Parent Corporation ,
Tax Liability ,
Tax Planning ,
Tax Treaty
Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning -
On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split -
Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty -
The Eleventh Circuit’s decision in Kroner v. Commissioner,...more
12/14/2022
/ Enforcement Actions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
Can digital asset or cryptocurrency investors that were customers or account holders in a failed cryptocurrency business claim a deduction for their digital asset or cryptocurrency loss? So far this year there have been four...more
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more
Serving process on a decentralized autonomous organization through its help chatbot? Introduction to Decentralized Autonomous Organizations - Web3.0 and the rise of decentralized technologies such as blockchain,...more
This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more