Individuals living outside of the US who inherit a US asset from a foreigner may be in for some surprises. If the decedent is an individual who is treated as a nonresident alien individual (NRA) for US estate tax purposes, his heirs often have a difficult time obtaining actual title to the US asset they … Continue reading The Federal Transfer Certificate: What Foreign Investors Into the USA Need to Know
It’s been no secret that the Internal Revenue Service (IRS) has cracked down on crypto. With many more taxpayers investing in cryptocurrencies the agency has targeted crypto investors who are often not complying with the US tax rules (many unknowingly). IRS “John Doe” subpoena activity of crypto exchanges has been successful with the biggies such … Continue reading Checked “YES” to the Crypto Question on Form 1040? Have NFTs? Get Ready….
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?
Imagine you are an American taxpayer living overseas. Like so many other Americans you are facing financial hardships wrought by COVID-19. You have a car loan you cannot pay and mounting credit card debt. Like an angel from above, your creditors agree to forever forgive some of the amounts you otherwise owe them. You cannot … Continue reading What a Mess: Debt Forgiveness and the American Abroad
Play it again (Uncle) Sam! Two US senators are trying yet again to enact a law mandating creation of a national database of beneficial owners of US businesses. So far we have seen two unsuccessful attempts by lawmakers for mandatory beneficial ownership registers in the USA. The latest borrows heavily from the two bills that have … Continue reading Lifting the Veil on US Shell Companies – Third Attempt to Force Beneficial Ownership Registers
Proud to announce publication of my article Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates in Tax Notes International (TNI) Vol. 98 No. 5 May 4, 2020. Available at no cost on SSRN. The article discusses the US tax treatment of the newest "foundations" … Continue reading Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates
As set out in detail in my earlier blog post, the CARES Act amended Internal Revenue Code section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a tax year beginning after December 31, 2017, and before January 1, 2021, to each of the five tax years preceding the tax … Continue reading IRS Provides CARES Act Guidance for Taxpayers with NOLs
On April 9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments
Right before Saint Nicholas’ Christmas visit, President Trump signed the "Further Consolidated Appropriations Act, 2020" to provide necessary funding to keep the federal government running through September 30, 2020. Included in the Appropriations Act was an additional piece of legislation commonly referred to as the “SECURE Act” (the full title is “Setting Every Community Up … Continue reading SECURE Act – Changes to Retirement Plan and IRA Rules – No More Big “Stretch”, Work Longer, Contribute More
Shame on the IRS! So abhorrent is the agency’s conduct in re-hiring employees who were fired for serious misconduct (think unauthorized access to taxpayer accounts, falsifying official documents, felony possession of a forgery device, lying about previous criminal convictions on employment forms, past tax problems including -“willful” tax noncompliance)- that Congress may have to step … Continue reading IRS Rehires Over 200 Previously Fired Employees – Makes a Mockery of Taxpayer Justice