Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

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 →

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 →

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 →

COVID-19 Relief: IRS Helps Foreigners Having Prolonged Presence in the US

In Rev. Proc. 2020-20, the Internal Revenue Service (IRS) provided relief to foreign citizens who were caught out by travel disruptions occasioned by the corona virus, and as a result, remained in the United States for too many days thereby causing them to be subject to US income tax. Under the Revenue Procedure, the IRS will … Continue reading COVID-19 Relief: IRS Helps Foreigners Having Prolonged Presence in the US →

Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test

Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE). In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE). Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test →

IRS Provides CARES Act Guidance for Taxpayers with NOLs

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 →

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 →

No FEIE/ Section 911 Exclusion – Taxpayers With a US “Abode”

With tax filing time looming, US taxpayers abroad should take heed when claiming the Section 911 “Foreign Earned Income” and “Foreign Housing Exclusion” benefits (FEIE). Two recent cases show how easy it is to lose the FEIE benefits granted to qualifying taxpayers living and working in a foreign country. (My blog post here explains the … Continue reading No FEIE/ Section 911 Exclusion – Taxpayers With a US “Abode” →

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 →