The Sunshine State is one of the lowest tax burden states in the US. Florida has no state individual income tax. At the state level, there is NO tax on social security benefits, retirement income, IRAs, 401(k) accounts,...more
3/19/2018
/ C-Corporation ,
Corporate Taxes ,
Florida ,
Franchise Taxes ,
Homestead Exemption ,
Income Taxes ,
Limited Partnerships ,
Property Tax ,
S-Corporation ,
Sales Tax ,
State and Local Government ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more
Since the early 1940’s, alimony payments have been tax deductible for the Payer Spouse. The recipient of the alimony (Recipient Spouse) paid the income tax on the alimony payments. The Tax Cuts and Jobs Act (TCJA) puts an...more
The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”...more
3/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
International Tax Issues ,
New Legislation ,
S-Corporation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Liability ,
Tax Planning ,
Tax Reform
The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...more
US Taxpayers (which includes US Citizens, Permanent Residents, Trusts, Estates, and Domestic Entities) with an interest in foreign financial accounts that meet the reporting threshold of an aggregate value exceeding $10,000...more
At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982...more
La "Ley de reducción de impuestos y empleos" (la "Ley") contiene una provisión que es una "acompañante hermana" de la Deducción por Dividendos Recibidos (DRD) que implica ventas o transferencias que envuelven un 10% de la ...more
The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign...more
La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...more
2/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
New Legislation ,
Passive Foreign Investment Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
El Departamento de Estado de los EE.UU esta requerido a denegar la solicitud de pasaporte de un individuo y está autorizado a revocar o limitar un pasaporte existente si el IRS certifica que el individuo tiene una deuda...more
The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...more
2/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
New Legislation ,
Passive Foreign Investment Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more
2/5/2018
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Repatriation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Conflicts of interest can arise at any time during a professional engagement. According to the American Institute of Certified Public Accountants (AICPA), “A conflict of interest may occur if a member performs a...more
The U.S Department of State is required to deny an individual’s passport application and is authorized to revoke or limit an existing passport if the IRS has certified that the individual has seriously delinquent federal tax...more
There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more
1/15/2018
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Foreign Ownership ,
IRS ,
Reporting Requirements ,
Required Forms ,
Tax Planning ,
U.S. Treasury
Possession of virtual currency, also known as cryptocurrency, is legal in the U.S. as well as many other parts of the world. The most well-known form of virtual currency is Bitcoin. There are other virtual currencies that...more
12/29/2017
/ 1099s ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
FATCA ,
FBAR ,
IRS ,
Popular ,
Tax Liability ,
Tax Planning ,
Virtual Currency
Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more
12/27/2017
/ 1099s ,
Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Fair Market Value ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Popular ,
Reporting Requirements ,
Section 6662 ,
Section 6722 ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
The US Tax Court is a Federal trial court established by Congress. It is independent from the IRS. The mission of Tax Court is to resolve disputes between Taxpayers and IRS. Tax Court has the authority to provide rulings on...more
When opening a new business, electing a business structure is an important decision. The business structure elected can affect how much will be paid in entity income taxes, record-keeping requirements, how much personal ...more
As a courtesy to Taxpayers, IRS provides an “early release draft” of an IRS tax form. The drafts are not to be used for filing, but are generally released when most changes have been incorporated into the Form. The...more
Taxpayers are not required to pay a negligence penalty for underpayment of income taxes if, under Internal Revenue Code regulations, there is reasonable cause for a position that the Taxpayer takes in an income tax return. ...more
Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more
Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more