Blog
IRS Releases New Guidance on the Repatriation Tax
The IRS released Frequently Asked Questions for the Repatriation Tax on March 13, 2018. Under FAQ 11, the IRS politely asked all individuals who have a repatriation tax issue not to electronically file Form 1040 until April 2, 2018. Well, here we [...]
Insights from across the Pond: Investing Tips for U.S.-UK Individuals
In March 2018, The Wolf Group caught up with Andrea Solana, Head of Advanced Planning at MASECO Private Wealth in the UK. Andrea has considerable experience advising high-net-worth individuals with financial interests in multiple countries and holds investment licenses in both the [...]
Planning a Move to the U.S.? Move These 4 Tasks Up Your Priority List
Preparing for an international move generally involves an extensive to-do list, topped by tasks such as finding a new home, choosing schools for the children, establishing a banking relationship, and figuring out transportation. If you are like most people, “tax matters” is [...]
Spotlight: International Tax Attorney Paul Marcotte, Jr. Opines on the End of OVDP
Paul Marcotte, Jr., Principal of law firm Paley Rothman, advises clients on complex international tax matters, including expatriation, structuring of offshore holdings, and cross-border estate planning, investments, and tax compliance. In this Spotlight, Paul addresses the top 3 considerations for individuals who [...]
The Ides of March 2018 – The end of OVDP!
On March 13, 2018, the IRS announced that the 2014 Offshore Voluntary Disclosure program, better known as OVDP, is coming to an end on September 28, 2018. The next few months will be the last opportunity taxpayers will have to avail themselves [...]
Consultants: Do You Qualify for the 20% Qualified Business Income Deduction?
Many of our clients are self-employed consultants who perform their consulting services both in and outside the United States. Many of these clients have asked us how the new tax reform law might affect them. Specifically, they are inquiring about whether they [...]
IRS to End Amnesty Program for Taxpayers with Unreported Foreign Financial Assets
The IRS announced yesterday that it would ramp down its current Offshore Voluntary Disclosure Program (“OVDP”) and entirely close the program on September 28, 2018. The OVDP is a partial amnesty program that generally allows U.S. citizens, green card holders, and U.S. resident [...]
It is Six of One, Half a Dozen of the Other – Changes to U.S. Shareholders and Downward Attribution
The Tax Cuts and Jobs Act of 2017 ushered in a host of tax provisions you may have heard of, including the Repatriation Tax,[1] GILTI,[2] and Base Erosion[3] taxes. But, there are some little-known changes that may make a big difference on [...]
2017 Tax Return Trap—More Reporting for Nonresident Taxpayers with Limited Liability Companies (LLC)
With recent tax reform dominating the news, many nonresident alien taxpayers may be unaware that other, older legislation has resulted in additional reporting requirements on their 2017 tax returns (and that failure to meet these requirements may result in steep penalties, of [...]
UK Attorney Mark Summers Weighs In on U.S.-UK Tax Issues (Part 2)
On August 14, 2017, TWG International Tax Director Mishkin Santa interviewed UK advisor Mark Summers on hot topics in U.S.-UK taxation. In the first part of this two-part series, Summers addressed common tax planning considerations. In this second part of the series, [...]
