Military Contractor Doesn’t Qualify for Foreign Income Exclusion

The Tax Court has held that an aircraft captain for a military contractor was not entitled to exclude under Code Sec. 911(a) income that he earned working in Afghanistan, finding that his “abode” was within the U.S. during his deployment. The Court also rejected the taxpayer’s argument that he nonetheless was entitled to the exclusion under Code Sec. 911(d)(4), which waives certain requirements for individuals who are required to leave a foreign country on account … Read More

Alimony Deduction Ending for Divorces After 2018

President Donald Trump’s 2017 tax overhaul eliminates the deduction for alimony payments — for divorces finalized starting in 2019. For many wealthy couples, reaching a deal by Dec. 31 could mean tens of thousands of dollars in tax savings every year. That’s pushing more of them to finally follow Sucherman’s advice and cooperate as the deadline nears. Divorce often means war for the top 1 percent. The richer you are, the more homes, possessions, investments … Read More

France Goes After Banks for Helping Taxpayers Cheat on Their Taxes

Following the USA Department of Justice efforts to convict a former bank executive for failing to comply with FATCA (see article here ), France is now increasing their efforts to track down and penalize those who attempt to evade their tax liabilities. Swiss bank UBS Group AG, its French unit and six executives faced charges of aggravated tax fraud and money laundering on Monday, the first day of a trial into allegations they helped wealthy … Read More

Getting Married? Consider Year-End Tax Planning

Prospective spouses have the opportunity to save money by taking income tax considerations into account before tying the knot. That’s particularly true for those who plan to marry late this year or early next year. As this article explains, from the federal income tax standpoint, some individuals marrying next year may come out ahead by either deferring or accelerating income, depending on their circumstances. Others may find it to their advantage to defer a year-end … Read More

Bank Executives being Targeted by Department of Justice

The Department of Justice is now targeting bank executives that are not complying with FATCA reporting requirements for their customers.  The following is the first bank employee who has been convicted of criminal charges. Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest, Hungary and Saint Vincent and the Grenadines, pleaded guilty to conspiring to defraud the United States by failing … Read More

RICs Can Postpone the Inclusion of Code Sec 965 Transition Tax to 2018

In a Revenue Procedure, IRS has allowed regulated investment companies (RICs) to postpone to 2018 the inclusion of the Code Sec. 965 transition tax in gross income, for purposes of computing the RIC required distribution. A regulated investment company (RIC) can be any one of several investment entities – for example, a mutual fund or exchange-traded fund (ETF), a real estate investment trust (REIT) or unit investment trust (UIT) – that is deemed eligible by … Read More

Offshore Voluntary Disclosure Program Ending Sept 28

On Mar. 26, 2009, IRS announced its first OVDP, a form of a tax amnesty program. It permitted U.S. taxpayers with unreported foreign accounts to avoid criminal charges and pay reduced civil penalties by making a voluntary disclosure to IRS. The first OVDP ran through Oct. 15, 2009. Thereafter, on Feb. 8, 2011, IRS announced a second OVDP. The second OVDP closed on Sept. 9, 2011. On Jan. 9, 2012, IRS reopened the OVDP, which … Read More