Today’s post looks at the case of Rost v United States, No 119-CV-0607-RP 2021 BL 435976 (WD Tex., Austin Div., September 22, 2021). In the Rost case, the Internal Revenue Service ("IRS") assessed close to USD597,000 in civil penalties for a US taxpayer’s failure to file IRS Forms 3520 and 3520-A, information reporting with regard … Continue reading Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out
Rich Americans…. Time to Wake Up!
Rich Americans (or foreigners with US assets), it's time to wake up and smell the coffee! Why? I am seeing more and more individuals with influence pushing for a change in the US tax laws so that wealth inequality becomes a thing of the past. Whether you agree with this position is not the point … Continue reading Rich Americans…. Time to Wake Up!
The Flexible “Foundation” – It’s Becoming a Thing!
Recently I was asked by another tax professional to discuss all things related to an entity called a “foundation” and I realized it would make for an interesting tax blog post. A foundation is a creature of a country’s statutory law, but foundations are not well understood in common law jurisdictions, such as the United … Continue reading The Flexible “Foundation” – It’s Becoming a Thing!
Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now
The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax. Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now