Guidance Related to Global Intangible Low Taxed Income

The Document linked to below contains proposed regulations implementing section 951A of the Internal Revenue Code. Section 951A was added to the Internal Revenue Code by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document also contains proposed regulations under sections 951, 1502, and 6038. These proposed regulations would affect United States shareholders of controlled foreign corporations. This document contains proposed amendments to 26 CFR part 1 under sections … Read More

New Crypto Tax Guidance May Be Coming Soon

“We’ll have guidance coming out very soon—could be within the next 30 days, could be even less than that,” Internal Revenue Service Commissioner Charles Rettig said May 30 at a Federal Bar Association conference. “I think it’s going to be helpful” for people who might be guessing at ways that digital assets might be nontaxable, he said. Practitioners are still relying on 2014 guidance, learn more about cryptocurrency taxes from this Dave Burton article.   … Read More

Tax Form Changes For Alimony Deduction Coming Soon

The IRS is planning to make changes to its tax return forms after the Treasury Inspector General for Tax Administration (TIGTA) found an additional line is needed on Form 1040.  This line is needed to enter the date of divorce or separation agreement on the form’s Schedule 1. Without the date of the alimony agreement on the form, the Internal Revenue Service will be unable to determine whether individuals claiming an alimony deduction are eligible … Read More

Individual US Shareholders of Controlled Foreign Companies Might Find Relief

The Internal Revenue Service and US Department of Treasury recently released proposed regulations that may provide relief to individual US shareholders of controlled foreign corporations” (CFCs). Currently, CFC’s are harshly taxed under the global intangible low-taxed incom (GILTI) rules enacted as part of the Tax Cuts and Jobs Act. The Proposed Regulations provide an individual US Shareholder of a CFC  who makes a “Section 962 election” the same 50% deduction from GILTI available to corporate … Read More

Converting to C Corp Due to TCJA

One year after the enactment of the 2017 tax legislation commonly known as the Tax Cuts and Jobs Act (TCJA), taxpayers continue to reconsider their historic choice of entity for federal income tax purposes. The significant reduction in the corporate tax rate (from 35% to 21%) brought about by the TCJA has many S corporations and partnerships  considering whether to convert to a C corporation to take advantage of the lower rate. Before electing to make the … Read More

Duplicative Offshore Reporting Rules Examined

The Government Accountability Office recently released a report questioning the rules for reporting offshore assets, claiming they are duplicative and should be streamlined. Nearly 75 percent of U.S. citizens with offshore assets reported their assets to the Treasury Department twice—to the Internal Revenue Service and to the Financial Crimes Enforcement Network (FinCEN), according to an April 1 report. “There are two information reporting requirements with the same information in the reports, and there is no … Read More

The Key Worldwide Foundation Contributors; The Charity in the College Entrance Exam Scam

The college admissions scandal involved many high profile people and shook up the world of college admissions practices throughout the country. William Singer, a college admissions consultant at the center of the college entrance scheme, which was uncovered by the IRS and FBI, pleaded guilty to racketeering and other charges on March 12, 2019. As a result, dozens of parents may now face steep tax penalties after they allegedly paid bribes disguised as donations in … Read More

New Tax Break for Exporting USA Goods

New IRS regulations issued March 4 make it easier for companies to claim a tax break for exporting their made-in-America goods and services. The release of the regulations give corporations a first look at what they need to do to claim a new deduction in the 2017 tax overhaul, which could lower their export income tax to about 13 percent from 21 percent. From airlines to defense companies, the Internal Revenue Service clarified that those … Read More