Avoiding PFIC Status – Practical Considerations

    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. A PFIC is any foreign corporation if – 75 [...]

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      Tax Cuts Are in the Air

      By Liubou Partnaya (Tax Senior Associate, Green Hasson Janks) With Donald Trump as President-elect, proposals presented during his campaign are brought to the forefront. Among his proposals are sweeping changes to our income tax laws. Here is a quick overview of individual and business tax reform [...]

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        The IRS’s International Focus

        By: Jason Booth For years now an ongoing debate has taken place on Capitol Hill about U.S. international tax policy reform. member at 35 percent) as well as improving our worldwide tax system’s “competitiveness” (compared to nearly all other OECD members’ territorial tax system). However, the [...]

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          F.I.C.A. Refunds From Severance Payments

          Our Tax Alert of Jan. 8, 2014 discussed potential refund claims to recover F.I.C.A taxes paid on severance payments made to former employees. The United States Supreme court issued a unanimous opinion on March 24, 2014 in which it determined that payments to laid off workers are subject to both [...]

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            Proposed Tax Changes from the “Green Book”

            The United States Treasury recently released the so-called "Green Book," which is the Administration's Fiscal Year 2014 Revenue Proposals. The Green Book is the President's wish-list of tax changes, and as usual, this year's wish-list is a cornucopia of tax proposals - past and present. The [...]

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              At the Cliff’s Edge

              Does tax policy change the way in which people behave economically? Could higher tax rates generate lower revenue to the government? This has been an age old tug of war amongst economists since the Kennedy administration proposed tax cuts in 1962, and the ushering in of the so called "Laffer Curve" [...]

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                The Looming Cliff

                The newest idiom in the American political lexicon is the "fiscal cliff.” It is all but certain to become a catch-phrase for the next fiscal iceberg facing the supertanker known as the U.S. economy. The fiscal cliff refers to approximately $1.2 trillion in automatic spending cuts coupled with [...]

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                  Benefits and Burdens of U.S. Citizenship

                  The name of Eduardo Saverin recently appeared on the Federal Register list of U.S. citizens who have renounced their U.S. citizenship. Saverin who was born in Brazil and currently resides in Singapore is best known as a Facebook co-founder and a soon-to-be billionaire. The motivation for [...]

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                    The Big Apple

                    On Monday, Apple announced that it is planning to pay a significant dividend to its shareholders for the first time since 1995. The dividend plan is being maneuvered through a maze of U.S. tax issues having to do with repatriating off-shore income. According to its latest regulatory filing, Apple [...]

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                      The IRS “Dirty Dozen”

                      On February 16, the IRS published its list of top 12 “tax scams” for 2012 dubbed the “Dirty Dozen.” “Taxpayers should be careful and avoid falling into a trap with the Dirty Dozen,” said IRS Commissioner Doug Shulman. “Scam artists will tempt people in-person, on-line and by e-mail with misleading [...]

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                        Tax proposals in the fiscal 2013 budget

                        On Monday February 13, 2012, the Administration submitted its fiscal 2013 budget proposal to Congress. The budget proposal contains changes to spending and deficit projections. As is true with all budget proposals, it includes an outline of future tax proposals by the administration. Here are some [...]

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                          Administration’s Corporate Tax Reform Proposals

                          The White House followed up the State of the Union address by releasing a fact sheet named “Blueprint for an America Built to Last” which highlights the administration's proposals for corporate tax reform and support for domestic manufacturing. The corporate tax reform is structured as a framework [...]

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                            A Worldwide Study on Tax Compliance

                            Paying Taxes 2012, an annual study by the World Bank, International Finance Corp. and PricewaterhouseCoopers, ranks 183 countries based on difficulty of compliance with business taxes. The study measures the tax systems by viewing a domestic company complying with the different tax laws in each [...]

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                              IRS Commissioner Lobbying for a Simpler Tax Code

                              In a recent speech at Harvard’s Kennedy School of Government, IRS commissioner Doug Shulman tried to make the case for tax simplification. In his prepared remarks he said “Most taxpayers want simplicity. They want to pay what they owe, understand what tax benefits they are entitled to, and not get [...]

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                                Where there is smoke…

                                Buried in the Tax Relief Act of 2010 was a provision that increased the lifetime gift tax exemption from $1 million to $5 million for each individual ($10 million for a married couple). This increase in exemption was provided for a period of two years and is slated to sunset on December 31, [...]

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