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 →

Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals

In the midst of the COVID-19 pandemic, most everyone is staying home; entertainment and meals outside the home bubble are not on the agenda. But, someday, life will return to normal and we will eat out again! The economy will pick up and clients, prospective customers and associates will look to meet and enjoy a … Continue reading Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals →

Tweets Rule…. Tax Filing Extended from April 15 to July 15 / What About FBAR?

While I was peacefully asleep in Dubai (we do have an 8 hour time difference to the East Coast of the USA), Secretary of the Treasury Steven Mnuchin announced in a tweet that “Tax Day” is being moved from April 15 to July 15. For those who fear that Tweets may not be a reliable … Continue reading Tweets Rule…. Tax Filing Extended from April 15 to July 15 / What About FBAR? →

Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”

Tax filing time is upon us! Selecting the best tax filing status is an important element of tax planning and should not be taken lightly. For US persons who are married to foreigners (so-called "nonresident alien individuals", or "NRA"), special considerations come into play. Making the decision how to treat your foreign spouse for US … Continue reading Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household” →

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! →

Business & Investment Structuring Between the USA and UAE

Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE →

Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light?

The Internal Revenue Service (IRS) - starting to see some light with respect to "foreign" pension plans? The US tax issues surrounding foreign pensions and retirement schemes is extremely complex and has vexed tax professionals and US persons abroad for many years. (Read my earlier blog post here). Due to the diversity of such plans, … Continue reading Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light? →

IRS’ Crypto Guidance – No, You Cannot Rely On It.

Cyptocurrency (such as Bitcoin) is a type of virtual currency. This is an emerging area and consequently transactions involving use of crypto come with an enormous amount of US tax uncertainty. The Internal Revenue Service (IRS) has taken a keen interest in virtual currency since its use provides a way for taxpayers to avoid tax … Continue reading IRS’ Crypto Guidance – No, You Cannot Rely On It. →

Cryptocurrency: Dissecting Revenue Ruling 2019-24 Treatment of Chain Splits

In this Tax Notes article published today, February 24, 2020 attorneys Arvind Ravichandran and Maurio Fiore, associates at the law firm Cravath, Swaine & Moore LLP, explain in fascinating detail the ABC’s of cryptocurrency, the workings of the mysterious blockchain technology and carefully dissect the IRS’ recent guidance enunciated in Revenue Ruling 2019-24. The article … Continue reading Cryptocurrency: Dissecting Revenue Ruling 2019-24 Treatment of Chain Splits →

Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II)

Part I of this blog post introduced the topic of the "foreign" pension or employee workplace savings plan, and examined in some detail how these plans are becoming more and more popular in the United Arab Emirates. The plans, however, give US expatriate employees some serious US tax headaches. Today's post focusses on these thorny … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II) →