Jason Booth

Principal

Jason Booth

About Jason Booth

Jason Booth has over 13 years of experience in public accounting and specializes in international tax consulting assisting both U.S. companies with operations overseas as well as non-U.S. companies with various U.S. inbound issues.

August 2017

What Tax-Exempt Organizations Should Know About Filing a Form 926

By | August 17, 2017|Categories: Nonprofit, Taxing Thoughts|Tags: , , , |

Many tax-exempt organizations invest frequently in foreign alternative investments (e.g., hedge, private equity, real estate and venture capital funds). When investing into such funds, these tax-exempt organizations’ primary tax concern is generally to mitigate their risk of Unrelated Business Taxable Income (“UBTI”). Funds commonly avoid this UBTI issue for their tax-exempt organization investors by structuring [...]

See Details

May 2017

Avoiding PFIC Status – Practical Considerations

By | May 3, 2017|Categories: Taxing Thoughts|

Overview: One area where complexities of U.S. taxation is clearly demonstrated is the Passive Foreign Investment Company (“PFIC”) rules.  These PFIC rules generally apply to U.S. investors in a foreign corporation where U.S. ownership is 50% or less.[1]  A PFIC is any foreign corporation if – 75 percent or more of the gross income of [...]

See Details

March 2017

Form 926 Filing Requirements – a Potential Trap for the Unwary Tax-Exempt Organization

By | March 31, 2017|Categories: Nonprofit, Taxing Thoughts|Tags: , , , |

By: Sunil Patel (Tax Supervising Senior) and Jason Booth (Tax Principal) Many tax-exempt organizations invest frequently in foreign alternative investments (e.g., hedge, private equity, real estate and venture capital funds). When investing into such funds, these tax-exempt organizations’ primary tax concern is generally to mitigate their risk of Unrelated Business Taxable Income (“UBTI”). Funds commonly [...]

See Details

Certain Entities Now Subject to the Form 8938 Filing Requirements

By | March 9, 2017|Categories: Taxing Thoughts|

Co-Authors Sunil Patel and Jason Booth Internal Revenue Service Form 8938, Statement of Specified Foreign Financial Assets, has been one of the primary reporting mechanisms imposed directly on taxpayers under the Foreign Account Tax Compliance Act (FATCA), which is designed to enhance tax reporting compliance with respect to certain foreign assets.  Form 8938 is used to report foreign [...]

See Details