Classification of Foreign Business Entities under U.S. Tax Law
An elementary question in business international taxation involves ascertaining the classification of foreign entities for U.S. tax purposes. This question emerges whenever a foreign business pursues U.S. economic activity or when a U.S. person establishes a business outside the U.S. While foreign entities enjoy definite classification under the laws of their respective countries of organization, their classification under U.S. tax law may be... Anthony (Tony) Malik, EA, MPAcc
How Can A Taxpayer Substantiate Expenses for Automobile Travel
David L. Charley and Julia A. Charley, Petitioners v. Commissioner of Internal Revenue, Respondent T.C. Memo. 2015-232 Filed December 2, 2015 A taxpayer may generally deduct from gross income the ordinary and necessary expenses of carrying on a trade or business that are paid... Steven R. Diamond, CPA
Our Lobbyists, Who Art in DC
2015 was an interesting year in many respects: the Patriots won Super Bowl XLIX and we all learned the numbers of pounds per square inch in a fully inflated football; Queen Elizabeth II became England’s longest reigning monarch; and the broad market bounced all over the place only to land where it began and to consign all of us consulting our 401(k) balances to yet another year at our desks. At the same time, 2015 was an i... Robert Kerr
Speaking the Same Language
Matt Groening, creator of The Simpsons, once lamented, “I know all those words, but that sentence makes no sense to me.” As an enrolled agent, you may mutter something similar to yourself as you scan through the latest IRC update for the umpteenth time. Then, once you master the tax jargon, you must translate it into layman’s terms and communicate with your clients. Challenging as this may be in English, some NAEA members go another step furt... Julia Shenkar
Streamlined Compliance Procedures for Non-disclosed Foreign Bank Accounts
With the global business environment changing, the world does not seem as vast. Advances in technology have increased awareness of different parts of the world and have made communication cheaper and more efficient. The U.S. citizen is now more mobile than ever before. Additionally, immigrants who may have thought the U.S. was an ultimate destination have begun to move back to their home countries because of equally attractive incomes and lif...