All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It

Under current law, limited partners who materially participate in a partnership's business are not subject to self-employment tax. Members of an S corporation who materially participate in the S corporation's business are subject to self-employment tax only on "reasonable compensation" received in their capacity as an “employee”. These individuals are also exempt from the 3.8% … Continue reading All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It →

An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications!

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published April 20, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com. Daily Tax Report International, published online here and in PDF format here. It has certainly been a year to remember. So many changes have … Continue reading An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications! →

GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

On November 8, 2020, I participated in a podcast with attorney John Richardson. We discussed some of the reasons why the incoming administration was likely to increase the pressure on Americans abroad. The podcast is here. On March 25, 2021 the Senate Finance Committee held a hearing on International Taxation. The hearing discussed changes to … Continue reading GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon →

Thinking of Moving Abroad? Here’s the Scoop with the Tax Girl and the Tax Lady

Looking to live under the Tuscan sun? Dreaming about Dubai? The pandemic has had many people considering a move. Many are looking at a move abroad. Kelly Phillips Erb, the @TaxGirl and I (@VLJeker , the @TaxLady_w_Style) had a great conversation about what it means from a tax and practical perspective for a US person … Continue reading Thinking of Moving Abroad? Here’s the Scoop with the Tax Girl and the Tax Lady →

Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date. The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way →

Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA

It’s finally here! We now have a new law mandating creation of a national database of beneficial owners of US businesses (and foreign businesses registered to do business in the US). It’s been a long time in coming and is being hailed as a huge anti-corruption and anti-money laundering reform . There have been several … Continue reading Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA →

IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

On November 5, the Internal Revenue Service (IRS) made life more difficult for taxpayers who may have missed some foreign information return filings. The IRS quietly revised one of the four options to correct for missing information returns with respect to a US taxpayer’s interest in any offshore/foreign assets and holdings (e.g., Form 8938, Form … Continue reading IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement →

WAKE UP CALL: Form BE-10

The Bureau of Economic Affairs (BEA) is a division of the US Department of Commerce. The BEA administers the so-called Form BE-10 survey, which is an intensive information gathering tool of the US government. The BE-10 is used to collect information on how US persons are investing abroad and on foreign investment in the US. … Continue reading WAKE UP CALL: Form BE-10 →

COVID-19: IRS Provides “US Trade or Business” / “Permanent Establishment” Relief for Foreign Businesses

As COVID-19 continues to wreak havoc across the globe, individuals and companies are being faced with new and very difficult challenges. One of the challenges involves unanticipated tax consequences that may arise as a result of travel disruptions and unintended stays in the US due to travel lock-downs. My earlier blog posts explained the US … Continue reading COVID-19: IRS Provides “US Trade or Business” / “Permanent Establishment” Relief for Foreign Businesses →

GILTI High Tax Kick-Out Election — Kicked Out by Dems!

On February 12, Senate Finance Committee Ranking Member Ron Wyden, D-Ore., and Senator Sherrod Brown, D-Ohio, introduced legislation to prevent the Treasury Department from carving out an exception (commonly called the GILTI High Tax Kick-Out) for multinational companies to escape the so-called GILTI provisions of the Tax Cuts and Jobs Act (TCJA). The title of the … Continue reading GILTI High Tax Kick-Out Election — Kicked Out by Dems! →