Are You a Foreign Agent? [More with McGlinchey, Ep. 21
On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more
Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
The Inflation Reduction Act of 2022 brought about modifications to the clean vehicle tax credit available under Section 30D of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Clean Vehicle...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more
Key Takeaways- While foreign investors are typically taxed on gain from the sale of U.S. real property interests (which include interests in most equity REITs), they are generally exempt from tax on gain from the sale of...more
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
El 3/11/22, el IRS-CI (Investigación Criminal del IRS) publicó su Reporte del Año Fiscal 2022 que destaca más de 2550 investigaciones criminales, una tasa de condena del 90%; acciones de cumplimiento enfocadas en el fraude...more
On 11/3/22, IRS-CI (IRS Criminal Investigation) released it FY2022 Annual Report highlighting more than 2,550 investigations, 90% conviction rate; enforcement actions focused on tax fraud, money laundering, cybercrimes, and...more
The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share your tax information with foreign...more