Reasonable Compensation: What Is It, Why Is It, and How the Heck Do We Get Our Clients to Understand It?
We doubt reasonable compensation compliance was part of your New Year’s resolution. However, the beginning of the year is the best time to address reasonable compensation with your clients. Getting all your ducks in a row now will make the end of the ... Paul S. Hamann and Jack Salewski, CPA
An Inquiry Into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers
Foreign corporations (FCs) often have varying degrees of U.S. business activities which in turn subject them to varying degrees of U.S. tax exposure. Anthony (“Tony”) Malik, EA
The Tax Cuts and Jobs Act Moves the U.S. Closer to a Territorial Tax System
The Tax Cuts and Jobs Act (TCJA) fundamentally changes the taxation of outbound activities of U.S. corporations and foreign corporations doing business in the U.S. and moves the U.S. international tax regime closer to a territorial system on par with other developed countrie... Sean Clancy, JD; Frank Emmons, JD; Shahzad Malik, JD
Impact of Tax Reform on Choice of Entity
The tax reform legislation known as the Tax Cuts and Jobs Act that was passed by Congress and signed by President Trump on December 22, 2017, has significantly changed how many businesses and their tax advisors approach the choice of entity decision. When deciding on how to be cla... Timothy C. Smith, JD
Undisclosed Foreign Accounts: Protecting the Executor
An executor administering an estate with undisclosed foreign accounts is exposed to substantial risks that may not be apparent. The following discussion is intended for executors and administrators who wish to understand and avoid those risks.1 A Typical Scenario A taxpayer dies. An executor is appointed and learns of foreign accounts: Tose foreign accounts hold investments. The ... Frank Agostino, Esq., Nicholas R. Karp, EA, USTCP
Taxation of Dividends From Foreign Corporations
U.S. persons frequently own legal entities abroad to pursue a variety of economic interests. Common U.S. ownership scenarios include expatriates forming foreign entities to locally operate businesses, U.S. residents forming foreign entities to capitalize on expansion opportunities, and entrepreneurial immigrants coming to the U.S. More often than not, these foreign entities default to corporate status à la the tax law’s default classification... Anthony (“Tony”) Malik, EA