By now most of my readers will have some familiarity with Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017. My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month
Category: Transition Tax / Deemed Repatriation Tax
Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments
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
COVID-19 and Losses, Losses, Losses ….NOL Tax Relief from the CARES Act
On March 25, 2020, the Senate unanimously passed (96-0) the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) providing desperately needed relief to, among others, individuals and businesses suffering economic distress wrought by the COVID-19 pandemic. Two days later, March 27, 2020, the House of Representatives passed the CARES Act by voice vote and President Trump signed … Continue reading COVID-19 and Losses, Losses, Losses ….NOL Tax Relief from the CARES Act
Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief
NEWS FLASH! The Internal Revenue Service (IRS) announced today that there are limited circumstances in which it may be appropriate to provide relief from "double taxation" resulting from application of the repatriation tax under Internal Revenue Code Section 965, as amended by the Tax Cuts and Jobs Act (TCJA). The IRS has determined that in … Continue reading Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief
IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)
Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”. In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)
Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation
Recently, a debate took place on the merits of the United States' income tax regime which is based on "citizenship". This lively debate was between the esteemed John Richardson (a US and Canadian attorney) and Professor Edward Zelinsky (a tax scholar and professor at Cardozo Law School in New York City). You can watch the … Continue reading Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation
US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”
Regular readers of my tax blog will not be surprised by the title of this post and the content it hints at delivering. They likely realize by now that the American person abroad is not looked upon favorably by the US tax laws. The tax laws look at anything “foreign” with a jaundiced eye when … Continue reading US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”
Section 965 “Transition Tax”: It’s Time to Pay the Piper
Copied below is my post as it appeared (March 21 2018) on my former blog "Let's Talk About US Tax" when hosted by Anglo Info. By now I suspect many of my readers have heard about (and are shedding tears over) new Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by … Continue reading Section 965 “Transition Tax”: It’s Time to Pay the Piper
Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One
Copied below is my blog piece originally posted on AngloInfo "Let's Talk About US Tax" posted on April 4, 2018 by Virginia La Torre Jeker J.D., Most readers have some familiarity by now with new Internal Revenue Code Section 965 and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). Introductory detail about this new … Continue reading Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One
Tax Primer: US Expats & Foreigners
Everything you need to know about US tax is right here at your fingertips! My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners