In a recent case, the Court of Federal Claims disagreed with two district courts that decided earlier in 2018 that the civil penalties for willfully failing to file a “Report of Foreign Bank and Financial Accounts” (FBAR) must be capped at $100,000. The Claims [...]
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 [...]
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 [...]
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) was due [...]
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 [...]
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 U.S. and [...]
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 likely pretty [...]
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 may want [...]
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 of the [...]
