The Tax Cuts and Jobs Act (TCJA) made significant changes to U.S. tax law, including various aspects related to international issues. An important example is cross-border estate planning for non-U.S. families who have one or more U.S. beneficiaries and U.S. investment accounts. These families [...]
On August 1, 2018, the Internal Revenue Service (IRS) announced the proposed regulations[1] for Internal Revenue Code §965 (Transition or Repatriation Tax). The proposed regulations are broken down into several sections. The areas and issues that are affected the most by the proposed regulations [...]
The 2018 Reebok CrossFit Games just came to an end. There are many categories of competition, but the main draw is the individual competition for men and women. The two winners are deemed “The Fittest (Man or Woman) on Earth.” In the men’s category, [...]
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 the U.S. [...]
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 into effect [...]
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 international corporate [...]
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 Tax Compliance [...]
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 the Internal [...]
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 are, and [...]
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 qualify for [...]
