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Nonresidents, Think You Are Safe from U.S. Gift and Estate Taxes? Think Again.
Do you live in the U.S. on a nonresident visa (e.g., G-4, A, or J visa)?Do you live outside the U.S. but own U.S. real estate or investments?Did you give up your green card or U.S. citizenship but maintain property or accounts [...]
Nonresidents: Do You Qualify for the 20% Qualified Business Income Deduction?
Many self-employed foreign nationals perform consulting services in the U.S. on an infrequent basis. As such, they may not accrue enough days in the U.S. to be considered tax resident under the so-called Substantial Presence Test. Instead, these individuals are nonresidents of [...]
Moving for a Job Just Got a Lot More Expensive
Taxpayers have been subject to the new U.S. tax rules under the Tax Cuts and Jobs Act (TCJA) for almost half a year now. TCJA has changed the way qualified job-related moving expenses are treated for tax purposes. This new legislation went [...]
Gazing into the IRS Crystal Ball—What Is Next on the IRS’s Hit List ?
Over the past 6 months, several major changes have had a significant impact on the tax industry. First, the Tax Cuts and Jobs Act of 2017 (TCJA) was passed in late December 2017. TCJA ushered in a new era of domestic and [...]
SPOTLIGHT: International Tax Attorney David H. Gershel
How Tax Reform Has Changed the Structure and Planning for Nonresident Aliens with U.S. Real Property Interests Wolf Group International Tax Director Mishkin Santa recently interviewed International Tax Attorney David Gershel to solicit his perspectives on how the Tax Cuts and Jobs Act [...]
The Wolf Group Celebrates 35 Years! Our Story—A Look Back and a Glance Forward
Founder Len Wolf 's mother visits him in his early office space. It was time. The year was 1983, and I was a young, single guy, successfully employed as an accountant with a growing, mid-size Northern Virginia defense contractor. I [...]
Thinking About Giving Up Your Green Card? Tax Reform Provides New Opportunities
A near-record number of U.S. citizens and green card holders expatriated in calendar year 2017—5,133 as reported by the IRS[1]—and this list is widely considered to undercount the true number of expatriates. In fact, since 2010, when Congress passed the Foreign Account [...]
IRS Offers First Amnesty Program for the Repatriation Tax
When tax reform was passed last December, the new legislation included a requirement for certain individuals with an interest in a foreign corporation to calculate and report a Repatriation Tax on their 2017 tax returns. This tax (or the initial installment payment) [...]
Planning Considerations for Global Families: Navigating IRC §2801 Inheritance Tax and Multi-Jurisdictional Transfer Taxes
While individuals expatriating from the U.S. often consider the income tax impacts of expatriation, few have a clear understanding of the U.S. gift and estate tax implications that their families may face should they, as a covered expatriate[1]: Make gifts or bequests [...]
GILTI Planning for Individuals – Reduce Your New Tax Rate by Double Digits
If you are an individual who owns or holds at least a 10% interest in a Controlled Foreign Corporation (CFC), you have probably spent the last 4 to 6 weeks working your CPA on how to calculate the new Repatriation Tax[1] under [...]